Corrective Action Plans

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The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
FINDING 2025-002 Finding Subject: Education Stabilization Fund – Wage Rate Requirements Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: (765) 522-6218 / tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Desc...
FINDING 2025-002 Finding Subject: Education Stabilization Fund – Wage Rate Requirements Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: (765) 522-6218 / tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Although the Education Stabilization Fund projects have been completed, the School Corporation will implement procedures to ensure compliance with Davis Bacon and wage rate requirements for all future federally funded grants that have this stipulation. Anticipated Completion Date: Immediately (February 1, 2026)
2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan ...
2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $586 in Subsidized Loans and $2,914 in Unsubsidized Loans; however, the College awarded the student $549 in Subsidized loans and $2,951 in Unsubsidized loans which resulted in an under award of $37 in Subsidized Loans and an over award of $37 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Waubonsee will ensure to add the loan fees first to ensure sub-loans are calculated correctly. Responsible Person for Corrective Action Plan Mary Greenwood Implementation Date of Corrective Action Plan 12/9/2025
1. Immediate System Correction The clock-to-credit hour conversion file in Banner (GTVSDAX) was reviewed and updated to include all applicable course prefixes, including MAH and PSY. This correction ensured that clock-to-credit hour conversions were calculated accurately for affected technical progr...
1. Immediate System Correction The clock-to-credit hour conversion file in Banner (GTVSDAX) was reviewed and updated to include all applicable course prefixes, including MAH and PSY. This correction ensured that clock-to-credit hour conversions were calculated accurately for affected technical programs. 2. Identification and Review of Impacted Students Financial Aid reviewed all students enrolled in the affected term (202610) and identified those whose federal aid hours had been overstated due to the conversion omission. 3. Correction of Federal Aid Awards Federal aid awards were recalculated for impacted students. The engagement team noted, and the College confirms, that all affected students were enrolled in a current payment period for which funds had not yet been fully drawn, allowing corrections to be made timely. 4. Resolution of Financial Impact Where recalculations resulted in reduced eligibility, institutional need-based funds were applied to affected student accounts to prevent students from incurring balances due to an internal administrative error. This ensured students were not financially penalized for the control deficiency. Preventive Actions and Controls to Avoid Recurrence To address the identified control deficiency and strengthen internal controls over clock-to-credit hour conversions, the College has implemented the following preventive measures: 1. Enhanced Curriculum Oversight The Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) now serve as standing members of the Academic/Curriculum Review Committee. This ensures that Financial Aid and Registrar review all proposed curriculum changes, including: o New courses o New course prefixes o Courses designated as “in degree plan” for technical or clock-hour programs This review occurs prior to course approval and implementation, allowing clock-to-credit hour implications to be addressed in advance. 2. Formal Notification and Review Process Academic Affairs will notify Financial Aid of any curriculum changes that may impact clock-to-credit hour conversions. Financial Aid will review and update Banner conversion tables as needed before federal aid calculations occur. 3. Assigned Responsibility and Monitoring Responsibility for maintaining and reviewing clock-to-credit hour conversion tables has been formally assigned to the Director of Financial Aid (Stacia Richerson). o Conversion tables will be reviewed each semester prior to awarding federal aid. o Discrepancies in ROAENRL will be reviewed promptly to ensure accuracy. 4. Ongoing Compliance Review The College will perform periodic reviews of conversion logic and awarding calculations to ensure continued compliance with federal regulations and internal control standards under 2 CFR 200.303. Conclusion Reid State Technical College has corrected the clock-to-credit hour conversion issue, resolved the related questioned costs, and implemented strengthened internal controls. The addition of the Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) to the Academic/Curriculum Review Committee, combined with formalized review and notification procedures, provides reasonable assurance that clock-to-credit hour conversions will be accurately applied prior to federal aid calculation and disbursement.
Management will have a heightened awareness of the deposits and transfers made from the EDA CARES Act RLF bank account. Management will ensure that loan payments are transferred to the EDA CARES Act RLF bank account in a timely fashion. Northeast Nebraska Economic Development District redrafted and ...
Management will have a heightened awareness of the deposits and transfers made from the EDA CARES Act RLF bank account. Management will ensure that loan payments are transferred to the EDA CARES Act RLF bank account in a timely fashion. Northeast Nebraska Economic Development District redrafted and resubmitted their ED-209 forms on December 18, 2025.
Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to...
Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to work to enhance our grant monitoring, including resuming management team meetings to keep everyone abreast of the status of grants. In addition, we will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements. Proposed Completion Date: June 30, 2026
Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will wor...
Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will work together and will resume management team meetings to determine and monitor the duties for which each is responsible. Strides have been made in this regard, as the principals have become involved in Federal program training, budgeting, and scheduling. Although the aforementioned report submissions are delinquent and funding was suspended, some filings have been completed, and certain payments have been received and others are forthcoming. However, management will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements. Proposed Completion Date: June 30, 2026
Finding Summary: When a recipient of Title IV assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must calculate the correct amount of Title IV grant or loan assistance that the student earned based on the ...
Finding Summary: When a recipient of Title IV assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must calculate the correct amount of Title IV grant or loan assistance that the student earned based on the student’s withdrawal date and allocation of Title IV funds and return unearned funds to the Department of Education within 45 days. During the fiscal year 2025 period, one student that withdrew during the Fall term required a return of Title IV funds. However, the funds were not returned to the Department of Education within the required timeframe. Corrective Action Plan: Student Financial Aid management has developed a new master return of Title IV spreadsheet to ensure the return of funds and is routinely monitored by three different members of the Financial Aid Team. Anticipated Completion Date: The procedures will be implemented for the 2025-2026 Financial Aid Year. Responsible Parties: Ron Anderson
Due to the oversight of the fractional CFO, other priorities had taken precedence over other financial matters. However, with the recent appointment of a full-time CFO specifically focused on CICOA's financial operations, we can now shift our attention back to these important reporting responsibilit...
Due to the oversight of the fractional CFO, other priorities had taken precedence over other financial matters. However, with the recent appointment of a full-time CFO specifically focused on CICOA's financial operations, we can now shift our attention back to these important reporting responsibilities. The full-time CFO will ensure that all financial reporting deadlines are respected and met in a timely manner, allowing for greater accuracy and accountability in our financial practices. This change will help us enhance our financial oversight and maintain the integrity of our reporting processes moving forward.
Management’s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its policies and procedures to ensure that not only a...
Management’s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its policies and procedures to ensure that not only are status changes reported to the Clearinghouse, but also that the enrollment changes are reported appropriately from the National Student Clearinghouse to NSLDS. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and implement controls, including multiple layers of review, to ensure that timely and accurate enrollment reporting is made. Furthermore, the reporting data was appropriately updated subsequent to the required timeframe. Name of Responsible Person: Jennifer O’Linger, Director of Student Financial Aid Implementation Date: Immediately
FINDING 2025-006 Finding Subject: Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials:...
FINDING 2025-006 Finding Subject: Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We were unaware of the required documentation at the onset of the ESSER grants. We were made aware during an ESSER construction monitoring audit. We made necessary changes per our corrective action plans from that audit for any future projects. Anticipated Completion Date: July 1, 2026
FINDING 2025-005 Finding Subject: Education Stabilization Fund – Earmarking Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of...
FINDING 2025-005 Finding Subject: Education Stabilization Fund – Earmarking Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will be mindful of federal requirements in the future. We will label earmarked expenditures when setting up our accounts to more clearly document our expenditures. Anticipated Completion Date: July 1, 2026
FINDING 2025-005 Finding Subject: COVID-19 – Education Stabilization Fund – Special Test and Provision - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org View...
FINDING 2025-005 Finding Subject: COVID-19 – Education Stabilization Fund – Special Test and Provision - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Education Stabilization Fund grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026
FINDING 2025-006 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Feder...
FINDING 2025-006 – Federal Direct Loan Eligibility Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: $484, net Condition Found: The amount of subsidized Federal Direct Loans awarded was incorrect for four of the ten students in our sample that received Federal Direct Loans. In addition, the two of the students was eligible for additional Federal Direct Loan funds. Corrective Action Plan: For the first student, the student was eligible to receive $5,500 of subsidized funds, but only $4,500 was requested. The University gave the student an additional $1,000 of institutional funds to cover the difference in the amount the student was eligible to receive and the amount requested from the Department of Education in December 2025. For the second student, the COD correctly shows the that $5,500 of subsidized aid was disbursed to the student. However, only $4,500 of subsidized loan funds were posted to the student’s account. An institutional scholarship of $1,000 was posted to the student account in December 2025. For the third student, $484 of subsidized loan funds were returned to the Department of Education in December 2025. For the fourth student, the Director of Financial Aid will work with third party administrator to reclassify the subsidized loan funds as unsubsidized loan funds. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000
FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment sta...
FINDING 2025-005– NSLDS Reporting Program Name: Federal Direct Student Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: During our compliance testing, student enrollment status changes were reported to the National Student Loan Database System (“NSLDS”) timely for nine of the seventeen students selected for testing. Corrective Action Plan: A new Student Financial Aid Director was hired in July 2025. The Student Financial Aid Director and Registrar will work together to determine and report student enrollment status changes within the required timeframe to NSLDS. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000
FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients...
FINDING 2025-002 – Exit Interview Program Name: Federal Direct Loan Program ALN and Program Expenditures: 84.268 ($866,312) Award Number: P268K253315 Federal Award Year: July 1, 2024 to June 30, 2025 Questioned Costs: N/A Condition Found: Six of the seventeen federal student financial aid recipients in our sample did not complete or were not sent exit interview instructions to complete within thirty days of the student ceasing to be enrolled in the University at least half-time. Corrective Action Plan: A new Financial Aid Director was hired in July 2025. The Financial Aid Director will review the students in question to determine if exit instructions were sent after the thirty-day time period. If an exit interview has not already been sent, the Financial Aid will mail exit interview instructions to the students’ home address. In addition, the Director of Financial Aid will work with the third-party administrator to determine which entity is responsible for sending exit interview information to students. Anticipated Completion Date: The University anticipates the corrective action being completed by March 31, 2026. Contact Person: Brad Burnett, Director of Financial Aid 405-912-9000
Corrective actions were implemented for the Fall 2025 term to ensure all students are notified of Direct Loan disbursements and that sufficient documentation is maintained.
Corrective actions were implemented for the Fall 2025 term to ensure all students are notified of Direct Loan disbursements and that sufficient documentation is maintained.
Action Taken enCircle has officially adopted the policy that gift cards provided to foster parents will not be submitted for reimbursement until the receipts are returned by the parents. If they do not spend the entire amount, only the amount spent will be requested for reimbursement and enCircle wi...
Action Taken enCircle has officially adopted the policy that gift cards provided to foster parents will not be submitted for reimbursement until the receipts are returned by the parents. If they do not spend the entire amount, only the amount spent will be requested for reimbursement and enCircle will cover the difference from non-federal funds. enCircle is also considering other methods of helping parents purchase clothes for foster placements. Further, enCircle has evaluated the use of all allocation methods for expenses that impact federal grants and will be limiting allocations to only clearly explicit expenses to ensure only programmatic costs are billed. Further, enCircle has created a new service code within its Chart of Accounts to track programmatic administration costs separate from overall administration costs.
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College re-evaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explan...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College re-evaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Early in the 2024-25 fiscal year, the College learned that this finding related to manually reported graduates and withdrawn students. Graduates reported during the automated file submittal process were reported as graduating at end of term, while graduates reported manually were reported as graduating on the College’s actual commencement date (one day different than end of term). The Registrar is now consistent in reporting graduation dates using the end of term for all graduating students. As for the reporting of withdrawals, the Registrar now manually updates the enrollment status and effective dates in NSLDS to ensure accurate and timely reporting. The findings in this audit period occurred prior to the above changes being implemented. Name(s) of the contact person(s) responsible for corrective action: Austin Nyhof, Registrar Planned completion date for corrective action plan: June 30, 2026
FINDING #2025-001 (SF-425 Financial report – Late Submission) Responsible Party: Sara Hudson & Tonya Garber Anticipated Completion Date: November 1, 2025 (Implemented) Corrective Action Planned: Snowy Mountain Development Corporation has implemented updated procedures to ensure timely preparation, r...
FINDING #2025-001 (SF-425 Financial report – Late Submission) Responsible Party: Sara Hudson & Tonya Garber Anticipated Completion Date: November 1, 2025 (Implemented) Corrective Action Planned: Snowy Mountain Development Corporation has implemented updated procedures to ensure timely preparation, review, and submission of SF-425 Federal Financial Reports. Management reviewed current HRSA reporting requirements and established internal reporting deadlines that precede federal due dates. Reporting responsibilities and deadlines have been formally communicated to applicable staff, and management now monitors compliance with submission timelines to ensure reports are filed in accordance with federal requirements. This corrective action has been implemented for the current fiscal year ending June 30, 2026, and management anticipates compliance with SF-425 reporting requirements for future audits.
Compliance Requirement: Procurement, Suspension and Debarment Campus: Sacramento Recommendation: KPMG recommends the University implement controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension an...
Compliance Requirement: Procurement, Suspension and Debarment Campus: Sacramento Recommendation: KPMG recommends the University implement controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendations. The University will review and enhance its procedures and internal controls to verify the suspension and debarment status of all vendors prior to entering covered transactions, as well as maintaining evidence of the suspension and debarment check in the procurement file of each vendor. Estimated Completion Date: July 2026 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu
COMPLIANCE REQUIREMENT: Disbursements to or on Behalf of Students Campus: Fullerton, Los Angeles Recommendation: KPMG recommends the University provide proper training on the disbursement notification requirements and apply its existing policies and procedures. Corrective Action Plan: California Sta...
COMPLIANCE REQUIREMENT: Disbursements to or on Behalf of Students Campus: Fullerton, Los Angeles Recommendation: KPMG recommends the University provide proper training on the disbursement notification requirements and apply its existing policies and procedures. Corrective Action Plan: California State University, Fullerton The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely disbursement notification. Estimated Completion Date: March 2026 Contact person: California State University, Fullerton Nick Valdivia Director of Financial Aid nvaldivia@fullerton.edu (657) 278-3064 Justin Chan Associate Director of Accounting Services & Financial Reporting juschan@fullerton.edu (657)278-8371 Corrective Action Plan: California State University, Los Angeles The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely disbursement notification. Estimated Completion Date: June 2026 Contact person: California State University, Los Angeles Linda Lopez Director, Financial Aid and Scholarships (323) 343-3247 llopez148@calstatela.edu
COMPLIANCE REQUIREMENT: Enrollment Reporting Campuses: Sacramento, Los Angeles Recommendation: KPMG recommends the University provide proper training on the enrollment reporting procedures and apply its existing policies and procedures. Corrective Action Plan: California State University, Sacramento...
COMPLIANCE REQUIREMENT: Enrollment Reporting Campuses: Sacramento, Los Angeles Recommendation: KPMG recommends the University provide proper training on the enrollment reporting procedures and apply its existing policies and procedures. Corrective Action Plan: California State University, Sacramento The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely and accurate reporting to NSLDS. Completion Date: December 2025 Contact person: California State University, Sacramento Tabitha Leeds Senior Director of Accounting Services (916) 278-4679 leeds@csus.edu Corrective Action Plan: California State University, Los Angeles The University concurs with the recommendation. The University will review and enhance its procedures to ensure timely and accurate reporting to NSLDS. Estimated Completion Date: June 2026 Contact person: California State University, Los Angeles Linda Lopez Director, Financial Aid and Scholarships (323) 343-3247 llopez148@calstatela.edu
Condition The internal controls over compliance were not operating effectively as a loan was disbursed to a business which operates outside of the approved county listing set by the SBA. Corrective Action Plan Corrective Action Planned: The Foundation had 26 approved counties across the lower half o...
Condition The internal controls over compliance were not operating effectively as a loan was disbursed to a business which operates outside of the approved county listing set by the SBA. Corrective Action Plan Corrective Action Planned: The Foundation had 26 approved counties across the lower half of Michigan for businesses eligible to be funded by SBA loan capital. MWF assigned SBA funding to an applicant that was initially identified as being in an eligible county. However, by the time of the loan closing, the applicant had settled on a brick and mortar store located in a county that is not on MWF’s SBA approved list. MWF has created a procedure for loans assigned to SBA as the loan capital funding source to verify before closing that the county for the business is in an SBA approved county. The Foundation has also received approval from the SBA to fund loans for business in the previously unapproved county subsequent to year end. Name(s) of Contact Person(s) Responsible for Corrective Action: Tamara Jackson, the director of lending, will verify all loans assigned to SBA loan capital prior to closing the county of the business and confirm it is an eligible county for MWF Anticipated Completion Date: The procedure described above was created, MWF’s credit policy and MWF’s closing checklist reflect this procedure which was implemented in the first quarter of FY2026.
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