Corrective Action Plans

Finding 388467 (2023-003)

Significant Deficiency 2023

NJ

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

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates...

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates reflect the actual disbursement date. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024

View Audit 300191

Finding 388461 (2023-002)

Significant Deficiency 2023

Brooklyn Law School

NY

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the ...

2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition: For one out of 25 students sampled, the effective date reported in NSLDS was incorrect. For four out of 25 students sampled, the status change was not reported in NSLDS in the next enrollment report or within 30 days of the date of determination. Cause: The Law School does not have a formalized policy to address enrollment reporting for summer terms. Effect: Enrollment reporting was inaccurate. Federal loan servicers utilize this information to determine the appropriate status for repayment terms and as such, had incorrect information. Enrollment reporting was not submitted within the required time frame. Questioned Costs: None. Context: See condition above. Recommendation: We recommend the Law School enhance their procedures and formalize a written policy for all terms of enrollment reporting. Corrective Actions Taken: Julie Brown, the Registrar will be given access to the NSLDS database to verify the information submitted through the National Student Clearinghouse is reported completely and accurately, particularly in relation to enrollment statuses that change during the non-required summer terms. This is part of an ongoing process as this information is updated multiple times per year. The Registrars Office will also draft a policy including timelines for uploading information to the National Student Clearinghouse and dates for verification of information in NSLDS. Responsible party: Julie Brown, Registrar. 718-780-7918 julie.brown@brooklaw.edu

View Audit 300177

Finding 388460 (2023-001)

Significant Deficiency 2023

Brooklyn Law School

NY

Questioned Costs Eligibility Significant Deficiency

2023-001 Program Eligibility—Significant Deficiency United States Department of Education - ALN 84.268 Federal Direct Student Loans Program Criteria: Students who receive federal student aid are required to be enrolled in an eligible program. Eligible programs must be included in an institution’s ac...

2023-001 Program Eligibility—Significant Deficiency United States Department of Education - ALN 84.268 Federal Direct Student Loans Program Criteria: Students who receive federal student aid are required to be enrolled in an eligible program. Eligible programs must be included in an institution’s accreditation and authorized by the State and the US Department of Education. Condition: The Law School disbursed federal student aid to 63 students, totaling approximately $2,115,747, enrolled in an ineligible program; the LL.M. program. Context: The impact was to 63 students over a four-year period. Cause: The Master of Laws (LL.M) Program was included in the Law School’s ECAR which was approved by the Department of Education. The Law School’s accreditation by the American Bar Association does not cover programs outside of the Juris Doctorate program. As such, the LL.M program was not properly accredited and therefore not an eligible program. The ECAR was subsequently amended to remove this program. Effect: Federal student aid funds were inappropriately disbursed to students in an ineligible program which resulted in the Law School entering into a settlement agreement with the U.S. Department of Education pursuant to which the Law School reimbursed and paid a fine to the US Department of Education. Questioned Costs: $2,115,747 Recommendation: We recommend the Law School review new or modified programs to ensure program eligibility requirements are met. Corrective Actions Taken: Upon notification from Department of Education regarding this concern, the Law School discontinued disbursement of Title IV funds to students of the LL.M. program and will not disburse those funds to students of that program until it receives additional accreditation. The Law School is currently working on obtaining accreditation from the Middle States Commission on Higher Education for its existing LL.M. and future Master’s degree programs. Responsible Person: David D. Meyer, President and Dean, (718) 780-7901, david.meyer@brooklaw.edu

View Audit 300177 Questioned Costs: $1

Finding 388456 (2023-003)

Significant Deficiency 2023

Colorado Mountain College

CO

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

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.068 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes ...

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.068 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar and Financial Aid departments have established a set schedule for enrollment reporting to the National Student Clearinghouse (NSC) and National Student Loan Database System (NSLDS) to ensure accurate and timely reporting happens each month and graduate reporting at the end of semester, within the 60-day window. To ensure CMC meets requirements to report all changes to enrollment and continuing enrollment within the 60-days, the monthly enrollment will follow best practice to submit every 30 days to allow time for correction of any errors prior to submission to NSLDS. The Student Affairs Systems Specialist will pull the enrollment report from CMC’s Student Information System (SIS) on the 19th for submission to NSC on the 20th of each month. If the 20th falls on the weekend it will be the Friday before. The Student Affairs Systems Specialist will correct any enrollment errors with NSC within 3 business days from the time of submission. The enrollment submission from NSC to NSLDS is scheduled for the 3rd of each month, and the Assistant Director of Financial Aid will pull a list from CMC’s SIS to match with NSLDS on the 15th of each month. If the 15th falls on the weekend it will be the Friday before. If there are any enrollment errors or missing students in NSLDS the Assistant Director of Financial Aid will notify the Student Affairs Systems Specialist to update student enrollment data within NSLDS. If there are no errors or missing enrollments in NSLDS, the Assistant Director of Financial Aid will send an email to the Student Affairs Systems Specialist to confirm the report is accurate and submitted. The graduate report will be submitted to NSC by the Student Affairs Systems Specialist on the second Friday after the end of the semester to allow for grade and graduation processing. The Assistant Director of Financial Aid will verify the graduate report within NSLDS two weeks after submission to NSC and email confirmation or request corrections with the Student Affairs Systems Specialist. Name(s) of the contact person(s) responsible for corrective action: Natalie Torres and Janelle Cook Planned completion date for corrective action plan: May 2024

View Audit 300168

Finding 388452 (2023-002)

Significant Deficiency 2023

Colorado Mountain College

CO

Questioned Costs Student Financial Aid Subrecipient Monitoring § 200.303

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Reco...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: CLA recommends that the College review the requirement and implement a monitoring control to monitor the checks throughout the year. In addition, for the checks outstanding greater than 240 days, the College should return the funding to the U.S. Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To enhance the 240 Day Outstanding refund check processing efficiency and compliance, a streamlined procedure was developed and implemented to monitor all uncashed refund checks, including those from federal aid sources. This process will involve utilizing an Informer report every two weeks to compile a comprehensive list of uncashed refund checks for current and prior terms. Upon identification, a system-generated communication will be promptly dispatched to students, notifying them of the outstanding refund check and providing clear instructions to contact the Business Office. Calculations will be performed to ascertain if the refund originates from a federal aid source. For students with federal aid-related outstanding refunds, outreach efforts will be undertaken. Additionally, a progressive maintained cumulative report will serve as a real-time monitoring mechanism to track the status of refunds and ensure timely compliance. Continuous open communication will be maintained with the Financial Aid and Compliance team, facilitating the provision of student refunds requiring action and fostering collaboration across departments to address any outstanding issues effectively. The above-detailed process has already proven effective and noticeably successful in addressing the challenges associated with uncashed refund checks, particularly those originating from federal aid sources. Moving forward, this process will be continuously optimized and refined as system enhancements allow. Regular evaluations will be conducted to identify areas for improvement and implement necessary adjustments, ensuring that the refund processing workflow remains efficient, compliant, and responsive to the evolving needs of both students and regulatory requirements. This commitment to ongoing optimization underscores our dedication to providing timely and accurate refunds while upholding the highest standards of financial stewardship and accountability. Name(s) of the contact person(s) responsible for corrective action: Renee McBride Planned completion date for corrective action plan: January 2024

View Audit 300168 Questioned Costs: $1

Finding 388448 (2023-001)

Significant Deficiency 2023

Colorado Mountain College

CO

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Reco...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the college reevaluate their procedures regarding the return of Title IV funds including the implementation of secondary review of calculations. This would prevent future errors, and provide a greater level of internal control. Additionally, we recommend they review policies regarding the timeliness and accuracy of student enrollment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CMC established a new secondary review procedure to help prevent future errors and provide a greater level of internal control regarding the return of Title IV funds (R2T4). Going forward, after an R2T4 is completed, the Quality Assurance (QA) review will be processed. As part of this review, the Financial Aid and Scholarship Coordinator will be notified that all R2T4’s have been completed for the current week. They will then pull up the spreadsheet of students who had an R2T4 completed and select at random at least 10% of the students on that list to review. In this review they will examine the following data for each of the selected students:  Each class for that semester including the name of the class, the dates the class took place, the credit load of the class, the last date of attendance (LDA) for each class, if the class counts towards the program, if the class was marked as never attended, and if the class should be used in the R2T4.  The Institutional charges to ensure the correct charges were used.  The Days attended vs Total days to ensure that any break of 5 or more days was removed. To document the review, the Financial Aid and Scholarship Coordinator will initial next to each class that they check as they review. The Financial Aid and Scholarship Coordinator will also review that the awards were updated in the Colleague AIDE screen correctly based on the calculation and ensure that any Post-Withdrawal Disbursement (PWD) or return is processed accurately. They will also verify that the Exit counseling request was sent to the student (this is indicated in the CRI screen). Once the review is completed, the Financial Aid and Scholarship Coordinator will initial and date the spreadsheet for the student that they performed the review on. They will then change the color on the spreadsheet tab to indicate that it was reviewed. Name(s) of the contact person(s) responsible for corrective action: Reilly Watanabe, JoAnna Hulett and Janelle Cook Planned completion date for corrective action plan: July 2023

View Audit 300168 Questioned Costs: $1

Finding 388434 (2023-011)

Significant Deficiency 2023

State of Hawaii, Department of Accounting and General Services

HI

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

Finding No. 2023‐011 – Earmarking (Significant Deficiency) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition The auditing firm noted the fo...

Finding No. 2023‐011 – Earmarking (Significant Deficiency) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition The auditing firm noted the following instances of noncompliance: -A total of 15.61% of funds were allocated for employment and training activities for adults and dislocated workers. -A total of 74.60% of funds were allocated for services to out of school youth. Current Status of Corrective Action Plan Concur. -Administrative Services Office (ASO) has communicated with Workforce Development Division (WDD) that no more than 15% of funds shall be allocated to provide employment training activities for Adults and Dislocated Workers. If there are recaptured funds to spend from the local areas for the program year, ASO and WDD will make sure that recaptured funds will not exceed the maximum requirements of 15%. -WDD shall monitor the progress of subrecipients to meet the minimum 75% expenditure for out of school youth. If necessary, a monthly or bi‐monthly meeting with subrecipients shall be scheduled to monitor the progress and take pro‐active recommendations and action to meet the requirements. Person Responsible Maricar Pilotin‐Freitas, Workforce Development Division Administrator Anticipated Date of Completion March 2024

View Audit 300162

Finding 388425 (2023-001)

Material Weakness 2023

Christus Health

TX

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles

Finding 2023-001 Federal Program Information Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: ...

Finding 2023-001 Federal Program Information Federal Agency: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing No.: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Award Period of Performance: July 1, 2020 to June 30, 2023 Corrective Action Planned: Management agrees that certain expenses to the COVID department were not reviewed and approved at the order entry level in specific cases. Although evidence of review was not retained for every charge to the COVID department, we believe the appropriateness of the charge was reasonable. Additionally, based on monthly review of departmental expenses and full-time equivalent (FTE) analysis at the facility level, we believe that these expenditures are subject to the appropriate level of review to identify unexpected variances. As it relates to the COVID Activity Code, this code was created as a means to track certain COVID hours worked, but was not configured to calculate the amounts associated with those hours, resulting in the need to make reasonable estimates. Even using the base pay rate at the time the hours were incurred would not have been accurate since it would omit adjustments for shift differentials, weekend hours, and overtime. We performed internal analyses and reviewed the results of samples selected by the auditors and concluded that the risk of a material overcharge to the program was minimal. Further, we have almost $40 million of unused lost revenues after our final PRF submission for Period 5, such that any questioned costs would easily be covered by other eligible uses of PRF funds. We have reviewed our processes related to the retention of expense documentation to improve audit evidence should this program ever be awarded in future periods. Responsible party: Lee Sonne, Vice President of Finance and Controller Implementation Date: Procedures were reviewed and analysis completed along with the Period 5 portal filing in September 2023.

View Audit 300159 Questioned Costs: $1

Finding 388424 (2023-002)

Significant Deficiency 2023

Catholic Community Services of Southern Arizona, Inc.

AZ

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Secondary Review of Billings (Significant Deficiency) Federal Agency: U.S. Department of Health and Human Services Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Federal Award Source: Pass-Through Funding Pass-Through Entity: Arizona Department of Economic S...

Secondary Review of Billings (Significant Deficiency) Federal Agency: U.S. Department of Health and Human Services Program Title: Child Care and Development Block Grant Assistance Listing Number: 93.575 Federal Award Source: Pass-Through Funding Pass-Through Entity: Arizona Department of Economic Security Pass-Through Identifying Number: SX222367 Criteria – Section §200.303 of the Uniform Guidance states that a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context – During our audit of allowable activities, we noted the Organization did not conduct a secondary internal supervisory review of the monthly billings for this program prior to submission to the funding source. Cause and Effect – Due to a shortage in staff, all 12 monthly billings for this program were prepared by one individual and were not reviewed and approved by secondary supervisory personnel. Questioned Costs – None identified. Recommendation – We recommend that the Organization improve its internal controls over the preparation of billings for this program to ensure all billings are reviewed and approved by secondary supervisory personnel. View of Responsible Officials: We agree with the finding. We have implemented procedures to ensure secondary reviews of all billings. See our Corrective Action Plan for the fiscal year ended June 30, 2023 for additional detail. Corrective Action Plan: CCS will improve its internal controls over the preparation of all billings. Effective April 1, 2024, Tammy Gallegos, CCS Accounting Manager, will make certain all billings are reviewed and approved by a secondary supervisor. The Accounting Manager will check off and sign off on a listing of all billings in an effort to ensure and document that 1) the billings were reviewed by a secondary supervisor, 2) the billings were submitted to the payers, and 3) the billings were submitted on a timely manner.

View Audit 300150

Finding 388410 (2023-101)

Material Weakness 2023

Santa Cruz County

AZ

Questioned Costs Matching / Level of Effort / Earmarking § 200.303

Assistance Listings number and program name: 17.259 WIOA Youth Activities Contact Person(s): Irasema Olvera, WIOA Director Anticipated completion date: June 30, 2025 To assist the County, meet the WIOA 75% earmarking requirement for out-of-school youth program, the County continues to d...

Assistance Listings number and program name: 17.259 WIOA Youth Activities Contact Person(s): Irasema Olvera, WIOA Director Anticipated completion date: June 30, 2025 To assist the County, meet the WIOA 75% earmarking requirement for out-of-school youth program, the County continues to develop written policies and procedures for its WIOA Youth Activities program. The County continues to provide eligible out-of-school youth the opportunity of paid work experiences (WEX). The County will also work with the pass-through grantor to develop an effective strategy to recruit and retain eligible out-of-school youth. Through the pass-thru grantor, the County requested a waiver of the of the 75% out-of-school youth program earmark ultimately seeking a more balanced 50% for the out-of-school youth program and 50% for the in-school youth program distribution. The County will continue to monitor the out-of-school services spending throughout the fiscal year and award period.

View Audit 300146 Questioned Costs: $1

Finding 388409 (2023-002)

Significant Deficiency 2023

Community Youth Advance

MD

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking

Planned Corrective Actions: The Community Youth Advance Interim Executive Director will make updates to the Employee Handbook and create a Standard Operating Procedures manual that outlines key responsibilities with regard to record keeping and reporting that will ensure continuity and stability dur...

Planned Corrective Actions: The Community Youth Advance Interim Executive Director will make updates to the Employee Handbook and create a Standard Operating Procedures manual that outlines key responsibilities with regard to record keeping and reporting that will ensure continuity and stability during times of leadership and staff transition. This will be reviewed with staff and our accounting firm to ensure it is comprehensive and addresses the organization’s needs and the recommendations of this audit. The Board of Directors will then review and give final approval of these documents. Name of the contact Person responsible for corrective action: Danielle Middlebrooks, Interim Executive Director, Community Youth Advance Board of Directors (Cassius Priestly, Chair) and Goldin Group CPAs Planned completion date for corrective action plan: The Standard Operating Procedures Manual and the Updated Community Youth Advance Employee Handbook will be completed and approved by June 30, 2024, to take effect July 1, 2024.

View Audit 300144

Finding 388403 (2023-002)

Significant Deficiency 2023

Heidelberg University

OH

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

Due to turnover in the financial aid office, verification was performed incorrectly prior to the employment of the current Director of Financial Aid. Since a new Director of Financial Aid has been employed, the verification tracking group of each student selected is reviewed prior to completing the ...

Due to turnover in the financial aid office, verification was performed incorrectly prior to the employment of the current Director of Financial Aid. Since a new Director of Financial Aid has been employed, the verification tracking group of each student selected is reviewed prior to completing the verification process to ensure each student is verified in accordance with the CPS assigned tracking group.

View Audit 300140

Finding 388399 (2023-001)

Significant Deficiency 2023

Heidelberg University

OH

Questioned Costs Student Financial Aid Special Tests & Provisions

The academic calendar used for return of funds calculations will be reviewed by a separate individual in the Financial Aid Office. We will review each calculation as it is completed to verify that the number of days in the semester have been reported correctly for each student.

View Audit 300140 Questioned Costs: $1

Finding 388361 (2023-002)

Significant Deficiency 2023

County of Los Angeles

CA

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.502 § 200.510

1. Person responsible: Director, Department of Public Health 2. Corrective action plan: DPH Finance agrees with this finding and recommendation. DPH will ensure to report Federal expenditures in the SEFA under the correct ALN based on Time Studies received. 3. Anticipated implementation date: Mar...

1. Person responsible: Director, Department of Public Health 2. Corrective action plan: DPH Finance agrees with this finding and recommendation. DPH will ensure to report Federal expenditures in the SEFA under the correct ALN based on Time Studies received. 3. Anticipated implementation date: March 7, 2024

View Audit 300135

Finding 388355 (2023-001)

Significant Deficiency 2023

County of Los Angeles

CA

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.502 § 200.510

1. Person responsible: Director, Department of Public Health 2. Corrective action plan: DPH Finance agrees with finding and recommendation. Finance will take the following corrective action: • Initiate direct, written communication with the Auditor-Controller to seek precise instructions and guida...

1. Person responsible: Director, Department of Public Health 2. Corrective action plan: DPH Finance agrees with finding and recommendation. Finance will take the following corrective action: • Initiate direct, written communication with the Auditor-Controller to seek precise instructions and guidance on the inclusion of accruals in our reporting. • Proactively review and document accrual procedures, ensuring alignment with regulatory requirements. • Prospectively include and implement accrual reporting in the Single Audit. • Establish a communication protocol with the Auditor-Controller to address any future uncertainties promptly. Through these measures, DPH aims to address the audit finding, establish clear guidelines for accrual reporting, and ensure compliance with reporting requirements while maintaining transparency and accuracy in our financial reporting practices. 3. Anticipated implementation date: April 1, 2024

View Audit 300135

Finding 388351 (2023-001)

None 2023

Thiel College

PA

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

Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2023 Criterion: Title IV regulations (34 CFR 685.309b) require t...

Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2023 Criterion: Title IV regulations (34 CFR 685.309b) require that upon receipt of an enrollment report from the Secretary, Institutions must update all information included in the report and return the report to the Secretary; (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an Institution must notify the Secretary within 30 days after the date the Institution discover that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the Institution and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the Institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition and Context: For one student out of 25 selected for testing, the College did not notify the NSLDS in a timely matter for a change in enrollment status. Cause and Effect: The College failed to follow its procedures for reporting student status changes. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate in NSLDS. Recommendation: The College should implement a process and related to verify with NSLDS that all enrollment status information for all students is updated accurately and timely. Recommendation: The College should implement a process and related to verify with NSLDS that all enrollment status information for all students is updated accurately and timely. Corrective Action Plan The College will continue to work with the NSC Audit Response Team, Office of the Registrar, and Office of Information Technology to resolve the data reporting issues we are currently experiencing. Denise Owens, Student Loan Specialist and Debra Schreiber, Registrar will work together to provide manual data reporting to NSLDS in an accurate and timely manner. Responsible Persons Michelle Work, Director of Financial Aid Denise Owens, Student Loan Specialist Dr. Laura Pickens, Associate Dean for Academic Programs and Records Debra Schreiber, Registrar Anticipated Completion Date This is an ongoing process and will begin immediately.

View Audit 300134

Finding 388348 (2023-006)

None 2023

Department of Education, State of Hawaii

HI

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

2023-006 Matching, Level of Effort and Earmarking – Control Deficiency View of Responsible Officials The Department generally agrees with the findings and recommendations. However, it should be noted that the earmarking findings described here are issues that were identified by the Department in ...

2023-006 Matching, Level of Effort and Earmarking – Control Deficiency View of Responsible Officials The Department generally agrees with the findings and recommendations. However, it should be noted that the earmarking findings described here are issues that were identified by the Department in June 2023 (prior to being audited) and a corrective action plan was put into place at that time. It had not yet been completed at the time of the audit and so was not reflected in the grant years that were used for this audit. Corrective Action Plan Note: As stated above, the earmarking issues raised by the audit were issues that had come to our attention in June of 2023. A corrective plan was established at that time. The steps for correcting these issues were begun June 21, 2023 but had not yet been completed at the time of the audit. The Corrective Action Plan being presented here is a modified version of this plan that encompasses the original plan as well as documents steps to address related issues raised in this audit. [TABLE] Contact Person: Kathleen Grondin, Title III Specialist English Learners Office Office of Student Support Services Anticipated Completion Date: July 30, 2024

View Audit 300126

Finding 388336 (2023-008)

Material Weakness 2023

State of Hawaii Department of Health

HI

Subrecipient Monitoring Matching / Level of Effort / Earmarking

Level of Effort Maintenance of Effort requirement was not met. Corrective Action Plan: AMHD and CAMHD have been in discussion with SAMHSA for the last few months about meeting the maintenance of effort requirement. This issue has not been resolved. Implementation Date: July 1, 2024 Responding Offici...

Level of Effort Maintenance of Effort requirement was not met. Corrective Action Plan: AMHD and CAMHD have been in discussion with SAMHSA for the last few months about meeting the maintenance of effort requirement. This issue has not been resolved. Implementation Date: July 1, 2024 Responding Official: Courtenay Matsu, MD, Acting Administrator, Adult Mental Health Division

View Audit 300124

Finding 388331 (2023-003)

None 2023

Limestone University

SC

Matching / Level of Effort / Earmarking

Finding 2023-003 U.S. Department of Agriculture-Community Facilities Loan and Grant, CFDA #10.766 Acting President and CFO created a quarterly reporting template that he completes and submits to the USDA to meet their reporting compliance requirements. In addition, he regularly communicates with USD...

Finding 2023-003 U.S. Department of Agriculture-Community Facilities Loan and Grant, CFDA #10.766 Acting President and CFO created a quarterly reporting template that he completes and submits to the USDA to meet their reporting compliance requirements. In addition, he regularly communicates with USDA representatives. Responsible Parties: Jeremy Whitaker, Acting President/CFO jwhitaker@limestone.edu 864-488-4539 DaOsha Pack, Controller dlpack@limestone.edu 864-488-4528 Summer Nance, Director of Financial Aid snance@limestone.edu 864-488-8251

View Audit 300119

Finding 388329 (2023-002)

None 2023

Limestone University

SC

Student Financial Aid Subrecipient Monitoring Reporting

Finding 2023-002- Student Financial Aid Cluster, Assistance Listing #84.063 and 84.268 Limestone University utilizes Jenzabar software to extract enrollment data to National Student Clearinghouse for reporting. Information was being reported to the National Clearinghouse, but in some instances, the ...

Finding 2023-002- Student Financial Aid Cluster, Assistance Listing #84.063 and 84.268 Limestone University utilizes Jenzabar software to extract enrollment data to National Student Clearinghouse for reporting. Information was being reported to the National Clearinghouse, but in some instances, the data was incorrect. Since the review of the findings, the Registrar has implemented the use of the field NSC Edit Student Data Records window, in addition to the normal enrollment process status indicated on the NSC Edit Registration Transactions window. A special status on the NSC Edit Student Data Records window will override the status on the NSC Edit Registration Transactions window. This change allows for more detailed monitoring of withdrawal dates to ensure what is being reported to NSC is accurate and timely. The Registrar reports enrollment status changes monthly to NSC to ensure enrollment changes are reported accurately and timely. The University reviewed the students in the finding, as well as reviewed all other students with the same status (withdrawn) and adjusted, if necessary, to ensure accurate student data was reported. Responsible Parties: Jeremy Whitaker, Acting President/CFO jwhitaker@limestone.edu 864-488-4539 DaOsha Pack, Controller dlpack@limestone.edu 864-488-4528 Summer Nance, Director of Financial Aid snance@limestone.edu 864-488-8251

View Audit 300119

Finding 388296 (2023-003)

Significant Deficiency 2023

Georgetown College

KY

Questioned Costs Student Financial Aid Eligibility

A. Comments on the Findings and Recommendations: The College concurs with the isolated finding of one instance out of the 40 FSA recipients tested ineligible funds were disbursed for a student failing to meet SAP standards. Auditor Recommendation: We recommend the College review the SAP status of al...

A. Comments on the Findings and Recommendations: The College concurs with the isolated finding of one instance out of the 40 FSA recipients tested ineligible funds were disbursed for a student failing to meet SAP standards. Auditor Recommendation: We recommend the College review the SAP status of all students at the end of each payment period to assess if students are properly or improperly in compliance with the SAP policy. B. Actions Taken or Planned: The College will follow the auditor's recommendation and review SAP statuses at the conclusion of each tuition payment period. The College recognizes this as an isolated incident and will continue to ensure the current SAP procedures are followed for all students by reviewing their standing at the conclusion of each pay period for SFA recipients. Multiple staff from varying departments will receive training as it pertains to reviewing SAP and the timeline it must be completed. Additionally, the third-party servicer will conduct internal control reviews on SAP each pay period. Status of Corrective Action Plan on Prior Year Audit Findings: All errors identified involving student records from the prior FSA Compliance Audit for the year ended June 30, 2023, have been satisfactorily resolved.

View Audit 300086 Questioned Costs: $1

Finding 388288 (2023-008)

Material Weakness 2023

Union Theological Seminary in the City of New York

NY

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

This Repeat Finding has been acknowledged. Union has completed its implementation of our Corrective Action Plan for this item, which involved entering into a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as ...

This Repeat Finding has been acknowledged. Union has completed its implementation of our Corrective Action Plan for this item, which involved entering into a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as well as education verification and authentication services. National Clearinghouse is the leading provider of educational reporting and data exchange, reporting on 97% of post-secondary student enrollments in the US. Union will be using a secure FTP process to send our enrollment data to NSC for timeline and consistent reporting to the National Student Loan Data System (NSLDS). As of January 2024, Union has completed the set-up and configuration of the new services. The new system will be managed by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Financial Aid. This back-up involves both the Academic and Financial Aid offices in order to improve our ability to address issues brought about by staff absences and/or turnover. UTS has completed enrollment reporting submissions via the NSC master service agreement on 12/20/23, 1/10/24, 2/05/24, 2/20/24 and 3/10.24 . Subsequent transmissions will continue to take place according to a pre-set schedule. This process includes email communication from NSC the week prior to an enrollment submission, confirmation of a successful submission and notification of potential errors. Union’s new Registrar, who has 17 years of experience, is also working directly with NSLDS to address errors found in past submissions and working with internal stakeholders in the Academic Office, Financial Aid Office, Bursar’s Office and IT Department to ensure that all student records accurately and correctly configured.

View Audit 300074

Finding 388278 (2023-001)

Significant Deficiency 2023

Peralta Community College District

CA

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Significant Deficiency § 200.303

Action taken in response to finding: The District continues to enlist the assistance of Huron and other vendors to assess our internal controls over financial aid federal awards. The district collaborates with external entities to engage in comprehensive training to district-wide staff involved in s...

Action taken in response to finding: The District continues to enlist the assistance of Huron and other vendors to assess our internal controls over financial aid federal awards. The district collaborates with external entities to engage in comprehensive training to district-wide staff involved in student financial aid processing. College FA staff are sent regular reminders to reconcile and perform R2T4 calculations. Management is actively recruiting to fill vacant positions in this area across the district. Planned completion date for corrective action plan: June 30, 2024.

View Audit 300059

Finding 388266 (2023-003)

Significant Deficiency 2023

Governors State University

IL

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

2023-003 FINDING: NONCOMPLIANCE WITH GRAMM-LEACH-BLILEY ACT Corrective Action Plan: The University is currently drafting the incident response plan and is working to secure a contract with an incident response firm. Additionally, the University recently hired an Information Security Analyst, a ne...

2023-003 FINDING: NONCOMPLIANCE WITH GRAMM-LEACH-BLILEY ACT Corrective Action Plan: The University is currently drafting the incident response plan and is working to secure a contract with an incident response firm. Additionally, the University recently hired an Information Security Analyst, a newly created position designed to address smaller-scale alerts and incidents. Responsible University Personnel: Charles Pustz, Associate Vice President for Information Technology Services and Chief Information Officer; David Weissbohn, Director of Information Security and Compliance. Anticipated completion date: Upon the Illinois Public Higher Education Cooperative’s (IPHEC) vendor decision and upon approved funding, ITS is hoping to have a firm engaged by end of Fiscal Year 2024.

View Audit 300046

Finding 388265 (2023-002)

Significant Deficiency 2023

Governors State University

IL

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

2023-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: The University has already identified a method to report directly to the U.S. Department of Education’s National Student Loan Data System (NSLDS) all enrollment changes occurring after the end of the term. The University will continue...

2023-002 FINDING: ENROLLMENT REPORTING Corrective Action Plan: The University has already identified a method to report directly to the U.S. Department of Education’s National Student Loan Data System (NSLDS) all enrollment changes occurring after the end of the term. The University will continue to update timely the NSLDS enrollment history as needed when the situation of late withdrawals occurs beyond the reporting dates. Responsible University Personnel: John Perry, Executive Director of Financial Aid/ Scholarships and Registration; Timothy Carroll, Registrar. Anticipated completion date: Already implemented.

View Audit 300046

Corrective Action Plans

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