Corrective Action Plans

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Corrective Action Plan: The Student Financial Aid Director corrected the enrollment status and withdrawal date for the students in question in November 2023. Procedures have been improved to ensure the information is communicated timely to the third-party servicer and that third-party servicer repor...
Corrective Action Plan: The Student Financial Aid Director corrected the enrollment status and withdrawal date for the students in question in November 2023. Procedures have been improved to ensure the information is communicated timely to the third-party servicer and that third-party servicer reports the changes to NSLDS timely. Anticipated Completion Date: The corrective action was completed in November 2023. Contact Person: Cliff Bristow, Director of Financial Aid 405-912-9037
View Audit 299875 Questioned Costs: $1
2023-005 Common Origination and Disbursement (COD) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reaso...
2023-005 Common Origination and Disbursement (COD) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Due to unforeseen technical issues and outdated procedures. Action taken in response to finding: The University is updating the procedures and internal controls to improve the timeliness of reporting. Hodges University is also working closely with our software providers to ensure the transmittals are working in both directions, and that the systems are communicating properly. Name(s) of the contact person(s) responsible for corrective action: Olker Alva, Director of Students Financial Services, and Diana Schultz, SVP of Student Affairs and Financial Services and Provost Planned completion date for corrective action plan: Effective immediately
2023-004 Return to Title IV (R2T4) Recommendation: We recommend that the University review its policies and procedures to ensure R2T4 calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned completion date for co...
2023-004 Return to Title IV (R2T4) Recommendation: We recommend that the University review its policies and procedures to ensure R2T4 calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned completion date for corrective action plan: Effective immediately Reason for finding: The University policies were not in alignment with the with the federal policies and best practices. Action taken in response to finding: Hodges University is updating its policies to follow the federal policies and best practices in order to remain compliant; that update will reflect as an addendum to the catalog. Name(s) of the contact person(s) responsible for corrective action: Nicole Hurley, Director of University Registrar, Olker Alva, Director of Students Financial Services, and Diana Schultz, SVP of Student Affairs and Financial Services and Provost
View Audit 299868 Questioned Costs: $1
2023-003 240-Day Requirement for Unclaimed Checks Recommendation: We recommend that the University review its procedures related to outstanding student checks to ensure they are being returned to the Department of Education within 240 days. Explanation of disagreement with audit finding: There is no...
2023-003 240-Day Requirement for Unclaimed Checks Recommendation: We recommend that the University review its procedures related to outstanding student checks to ensure they are being returned to the Department of Education within 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The University continuously attempted to refund the student checks. Action taken in response to finding: The Financial Aid and Student Accounts offices will work diligently to ensure the University's compliance with the federal regulations and deadlines regarding unclaimed properties. Name(s) of the contact person(s) responsible for corrective action: Olker Alva, Director of Students Financial Services, and Diana Schultz, SVP of Student Affairs and Financial Services and Provost Planned completion date for corrective action plan: April 30, 2024
View Audit 299868 Questioned Costs: $1
2023-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagr...
2023-002 National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Hodges University's enrollment and withdrawal policies did not align with the department of education requirements. In addition, internal controls in place were insufficient. Action taken in response to finding: Hodges University is updating its policies to follow the federal policies and best practices in order to remain compliant; that update will reflect as an addendum to the catalog. We have implemented additional internal controls to ensure the timeliness and accuracy of future reporting, and compliance. Name(s) of the contact person(s) responsible for corrective action: Nicole Hurley, Director of University Registrar, Olker Alva, Director of Students Financial Services, and Diana Schultz, SVP of Student Affairs and Financial Services and Provost. Planned completion date for corrective action plan: Effective immediately
Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: Cash Manag...
Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: Cash Management/ Matching, Earmarking, Level of Effort Views of Responsible Officials and Corrective Action: We concur with the finding. The City will implement procedures to include evidence documenting the individual who reviewed the reimbursement request prior to submission. Name of Responsible Person: Jennifer Hennessey, Director of Finance Projected Implementation Date: June 30, 2024
Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: Special Te...
Program: Nationally Significant Freight and Highway Projects Financial Assistance Listing Number: 20.934 Federal Agency: U.S. Department of Transportation Pass-through: California Department of Transportation Award Year: 2019 Grant Award Number: INFRALUL-5459(031) Compliance Requirements: Special Tests and Provisions - Wage Rate Requirements Views of Responsible Officials and Corrective Action: We concur with the finding. The City will implement controls to ensure there are procedures in place requiring the documented review of the certified payroll submitted by the construction contractors. Name of Responsible Person: Jennifer Hennessey, Director of Finance Projected Implementation Date: June 30, 2024
Program: Community Development Block Grants/Entitlement Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Views of Responsible Officials and Correctiv...
Program: Community Development Block Grants/Entitlement Grants Cluster Financial Assistance Listing Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Award Year: All Grant Award Number: All Compliance Requirements: Reporting Views of Responsible Officials and Corrective Action: We concur with the finding. The City will implement procedures to include evidence documenting the individual who reviewed and approved required reports prior to submission. Name of Responsible Person: Jennifer Hennessey, Director of Finance Projected Implementation Date: June 30, 2024
Action taken in response to finding: Create a third party verification policy and procedure SOP. Name(s) of the contact person(s) responsible for corrective action: Doryan Campo Planned completion date for corrective action plan: April 2024
Action taken in response to finding: Create a third party verification policy and procedure SOP. Name(s) of the contact person(s) responsible for corrective action: Doryan Campo Planned completion date for corrective action plan: April 2024
View Audit 299848 Questioned Costs: $1
Calumet Public School will ensure that the Davis-Bacon Act is followed. The district will conduct weekly and bi-weekly payroll report reviews on contractors and subcontractors. We will ensure that federal wage rates, as well as the fringes are being properly paid. The district will also have all ...
Calumet Public School will ensure that the Davis-Bacon Act is followed. The district will conduct weekly and bi-weekly payroll report reviews on contractors and subcontractors. We will ensure that federal wage rates, as well as the fringes are being properly paid. The district will also have all the required items posted at any jobsite. We are committed to complying with the Davis-Bacon Act.
FINDING 2023-002 Finding Subject: COVID 19 – Education Stabilization Fund - Reporting Summary of Finding: Material Weakness, Other Matters. Contact Person Responsible for Corrective Action: Steve Nauman, Treasurer Contact Phone Number and Email Address: Phone: 812-522-3340 Email: naumans@scsc.k12.in...
FINDING 2023-002 Finding Subject: COVID 19 – Education Stabilization Fund - Reporting Summary of Finding: Material Weakness, Other Matters. Contact Person Responsible for Corrective Action: Steve Nauman, Treasurer Contact Phone Number and Email Address: Phone: 812-522-3340 Email: naumans@scsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The SCSC management team will design and implement a proper system of internal control, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals and oversight are taking place prior to filing required reports. Anticipated Completion Date: The projected date of completion is February 29, 2024.
2023-006: Level of Effort – Supplement, Not Supplant (Significant Deficiency) Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Authority will put into place a system to regularly monitor the expenditure of all Federal funds to ensure that the...
2023-006: Level of Effort – Supplement, Not Supplant (Significant Deficiency) Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Authority will put into place a system to regularly monitor the expenditure of all Federal funds to ensure that the funds are not being used to supplant state funds. The SEP Manager will send a calendar invite to the Accounting Manager on a quarterly basis to review and assess all Federal fund activity. The review will be documented and signed by the Accounting Manager and the SEP Manager. Completion Date - June 2024 Contact Person - Jami Blosmo, Accounting Manager
2023-005: Reporting (Significant Deficiency) Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Authority requires the Accounting Manager to be a secondary reviewer and approver of the SF-425 reports before they are submitted to the U.S. Depart...
2023-005: Reporting (Significant Deficiency) Views of Responsible Officials and Planned Corrective Actions: Management concurs with the finding. The Authority requires the Accounting Manager to be a secondary reviewer and approver of the SF-425 reports before they are submitted to the U.S. Department of Energy. Going forward, the SEP Manager will send a calendar invite to the Accounting Manager for review of each SF-425 report. The Accounting Manager will date and document the report as being reviewed and approved. Completion Date - November 2023 Contact Person - Jami Blosmo, Accounting Manager
Finding 387727 (2023-001)
Significant Deficiency 2023
Finding Number: 2023-001 Condition: The College did not timely return the Title IV funds (R2T4) for 3 students. Planned Corrective Action: As outlined in the audit finding, the auditors noted three of the forty R2T4 transactions reviewed (7.5%) were not completed within the required timeframe. We h...
Finding Number: 2023-001 Condition: The College did not timely return the Title IV funds (R2T4) for 3 students. Planned Corrective Action: As outlined in the audit finding, the auditors noted three of the forty R2T4 transactions reviewed (7.5%) were not completed within the required timeframe. We have reviewed these transactions and agree with the auditor’s determination. Given that only three calculations were identified as late, we consider these to be anomalies and not reflective of our overall operating practice. As the auditors state, all three of these transactions were calculated correctly and were all three associated with the Fall term. Since that time, we have instituted new processes to help ensure the timely processing of all R2T4 calculations. These new processes include cross-training of staff to help ensure complete coverage of duties regarding this task. In addition, financial aid staff relating to R2T4 activities have received additional training with a financial aid consultant to help ensure both timeliness and accuracy. Contact person responsible for corrective action: Nicole Hatter, Executive Director, Advising and Financial Aid - nhatter@lakemichigancollege.edu - 269-927-8185 Anticipated Completion Date: 3/21/2024
Finding 387723 (2023-001)
Significant Deficiency 2023
Recommendation: We recommend the College evaluate its policies and procedures for identifying and reporting enrollment status changes to ensure that all changes are reported to NSLDS in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding....
Recommendation: We recommend the College evaluate its policies and procedures for identifying and reporting enrollment status changes to ensure that all changes are reported to NSLDS in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The College has recently updated their Student Information System (SIS) to a less manual program. Formerly, the College used SONIS, but as of February 2023 has moved to Jenzabar One (J1). The J1 system is more robust than the SONIS system and is interfaced with the Financial Aid Management (FAM) system the College uses – PowerFAIDS. With the capability of the systems communicating with each other, the College can implement real-time internal reconciliation that can quickly identify issues with the dates, amounts, etc. and will allow the departments to work quickly to resolve exceptions found related to compliance of the dates, amounts, etc. Since the change-over to J1, the reconciliation process has been more efficient and has allowed for quick resolution of discrepancies identified. Name(s) of the contact person(s) responsible for corrective action: Daphne Parks, Vice President of Processing at FAS; Stephanie Knight, Director of Enrollment Services & Financial Aid, Beacon College; Carrie Santaw, Registrar, Beacon College Planned completion date for corrective action plan: Completed.
Finding 387722 (2023-002)
Significant Deficiency 2023
Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In Beacon’s previous student bill...
Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: In Beacon’s previous student billing system (Sonis, in use until February 2023), Beacon had recuring difficulties posting certain transactions to student accounts, causing Financial Aid staff or the Jenzabar program administrator to work behind the scenes to get transactions entered. Since our conversion to Jenzabar J1, we have not encountered these difficulties. Secondly, a schedule of posting transactions to the student accounts has been established depending upon when the transaction is received from Financial Aid. This schedule should ensure that posting of transactions is performed timely and predictably. Name(s) of the contact person(s) responsible for corrective action: Daphne Parks, Vice President of Processing at FAS; Stephanie Knight, Director of Enrollment Services & Financial Aid, Beacon College Planned completion date for corrective action plan: Completed.
Finding 387681 (2023-002)
Significant Deficiency 2023
Assistant Director of Academic Data and Records will run a report on the last business day of the month to verify any students that have exited the institution from the prior two submission periods (last two months) have valid exit dates in the National Student Loan Clearinghouse. Any discrepancies ...
Assistant Director of Academic Data and Records will run a report on the last business day of the month to verify any students that have exited the institution from the prior two submission periods (last two months) have valid exit dates in the National Student Loan Clearinghouse. Any discrepancies will be corrected to ensure timely and accurate submission of student records from the Clearinghouse to NSLDS.
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no ...
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) The university completed phase one of the corrective action plan with the practice of matching the program begin date to the term date for new students last year. Accuracy is monitored with reports. No repeat findings found on this population of students. The audit recommendation focuses on continuing students. The university is now in the process of completing phase two, continuing students. Existing active programs will be manually updated by the Registrar’s Office; steps for resolution are already in progress. Using reports to capture students, the team will update the student information system, NSLDS, and NSC, correcting the program begin date to match the term date. This process change will align our reporting procedures with required regulations prior to the close of the 2023 fiscal year (July 2024). 2) The Registrar’s team will provide ongoing instruction to all personnel who have access to process program changes in the student information system. The instructions will direct users to match the begin date of the new program with the term; exceptions will be addressed in the communication. Changes will be monitored by the Registrar’s Office with daily reports. Repeat finding, see 2022-003, item 2. CAP phase 2 focuses on continuing students and is still in process, this involves identifying continuing students with mis-matched data and making the appropriate corrections. Name(s) of the contact person(s) responsible for corrective action: Elizabeth Vestal, Registrar. Planned completion date for corrective action plan: July 2024
Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with ...
Return to Title IV Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct withdrawal dates and are completed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The university is researching ways to ensure accuracy in the data entry of withdrawal dates into the system of record. The current process is manual data entry by advising staff creating an opportunity for human input error. Options are being reviewed and could include an integration between the system of record and the eForm the data is collected on or a report that will compare the withdrawal date entered into the system to the source data. Repeat finding, see 2022-002: CAP Completed. Prior year finding had to do with manual data entry directly into the R2T4 calculation. No repeat findings were found in this area of data entry. Name(s) of the contact person(s) responsible for corrective action: Brenda Clark, Director of Financial aid Planned completion date for corrective action plan: December 2023
View Audit 299743 Questioned Costs: $1
Name of contact person: Katie Langan Corrective action: With respect to the finding relating to program length issues, the College agrees with this finding and will make appropriate changes to ensure that the NSLDS records for program length are based on years, correcting the earlier issue of basin...
Name of contact person: Katie Langan Corrective action: With respect to the finding relating to program length issues, the College agrees with this finding and will make appropriate changes to ensure that the NSLDS records for program length are based on years, correcting the earlier issue of basing program length by weeks. With respect to the program change date record retention issue, the College agrees with this finding and will take appropriate actions to correct this issue. These actions will include retraining of staff to reinforce the necessity of retaining the records, providing adequate secure storage facilities for paper records and conducting regular quality control exercises to ensure that this issue does not re-occur. Proposed completion date: June 30, 2024
Finding 387659 (2023-001)
Significant Deficiency 2023
Prior to 2015-16, Perkins MPNs were paper promissory notes stored physically on campus. We have since moved to an electronic MPN process that has been utilized and stored with our third-party servicers, Campus Partners and then Heartland ECSI. The authority for schools to make new Federal Perkins Lo...
Prior to 2015-16, Perkins MPNs were paper promissory notes stored physically on campus. We have since moved to an electronic MPN process that has been utilized and stored with our third-party servicers, Campus Partners and then Heartland ECSI. The authority for schools to make new Federal Perkins Loans ended September 30, 2017. Middlebury has not lent Perkins Loans to borrowers since the 2017-18 academic year, thus not creating any new Perkins Loan promissory notes.
Ref 2023-007: Suspension and debarment checks should be performed prior to doing business with certain vendors Federal Agency: U.S. Department of State for Ethiopia South Sudanese Refugee Assistance V and VI; United States Agency for International Development (USAID) Program: Ethiopia: South Sudan...
Ref 2023-007: Suspension and debarment checks should be performed prior to doing business with certain vendors Federal Agency: U.S. Department of State for Ethiopia South Sudanese Refugee Assistance V and VI; United States Agency for International Development (USAID) Program: Ethiopia: South Sudanese Refugee Assistance V and VI; Ethiopia: BHA Tigray Child Protection Assistance Listing: 19.517 (Ethiopia); 98.001 (Ethiopia) Award #: SPRMCO21CA3181 ETH102315 (Ethiopia), SPRMCO22CA0199 ETH102389 (Ethiopia); 720BHA21GR00199 ETH102324 Award year: FY23 Pass-through: Plan USA, Inc. Management comments: Management agrees with the finding and recommendation. Although a policy and system was in place to properly search for vendor debarment for all covered transactions and to maintain adequate documentation of the search, the existing policy was not properly followed for these vendors. As such, management will focus on consistently executing the policies in place as well as provide trainings to ensure that staff understand and follow procedure. (Corrective actions will be introduced and completed by June 30, 2024. Chief Financial Officer, Celine Thibaut, +33672261874)
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District has modified the business practice for returning Title IV funds to improve the calculation of when funds are due and provided training to ensure multiple individuals are able to perform the neces...
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District has modified the business practice for returning Title IV funds to improve the calculation of when funds are due and provided training to ensure multiple individuals are able to perform the necessary procedures for returning Title IV funds. Implementation Date: 6-23-23
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District is conducting a review of its processes for NSLDS reporting to improve accuracy and has provided training to ensure multiple individuals are able to perform the necessary procedures for submittin...
Management's Response: We concur. View of Responsible Officials and Corrective Action Plan The District is conducting a review of its processes for NSLDS reporting to improve accuracy and has provided training to ensure multiple individuals are able to perform the necessary procedures for submitting NSLDS reports. Implementation Date: In Progress
The College has conducted a comprehensive review and update of its procedures for reporting Federal Direct Loan and Pell Grant disbursements to the COD system. The College has multiple program calendars which overlap our standard academic calendar, including two aid years concurrently during spring ...
The College has conducted a comprehensive review and update of its procedures for reporting Federal Direct Loan and Pell Grant disbursements to the COD system. The College has multiple program calendars which overlap our standard academic calendar, including two aid years concurrently during spring and summer sessions. We have identified the multiple start dates as a primary challenge with timely reporting and have initiated corrective actions to synchronize program dates more closely with the standard academic calendar. This includes the phasing out of a summer header student cohort to prevent similar issues in the 2024-2025 academic year. A bi-weekly reconciliation report has been created to review activity and identify early discrepancies to maintain better internal controls. During the 2021-2022 aid years, the Financial Aid office had four Financial Aid directors with different approaches to aid awarding strategy. The current Director is focused on refining processes to enhance internal controls. Additionally, the College recognized a need for staff professional development and training and engaged a Financial Aid consultant to review our systems and processes. The Financial Aid consultant now conducts quarterly assessments to help us maintain our setups and provides ongoing training for our team. These steps are in line with best practices and are part of our commitment to minimizing errors and conducting timely financial aid reporting. The College has made significant improvements. The number of selected records failing the 15-day COD reporting window decreased from 15 in FY22 to 4 in FY23.
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