Corrective Action Plans

Finding 395525 (2023-002)

Significant Deficiency 2023

PR

Student Financial Aid Special Tests & Provisions Eligibility

Institutional Comments on Findings and Recommendations: The institution agrees with the auditor on this finding in that there were (3) three cases where the enrollment status was not reported correctly. Although as was observed by the auditor, the enrollment status for the three students in questio...

Institutional Comments on Findings and Recommendations: The institution agrees with the auditor on this finding in that there were (3) three cases where the enrollment status was not reported correctly. Although as was observed by the auditor, the enrollment status for the three students in question were corrected in the next enrollment report that was submitted. During the audit period, the institution was unable to update, submit or complete in a timely manner Enrollment reports for the period of July through December 2022. This was mainly due to problems with the implementation of a new format for enrollment reporting through the NSLDS Modernized Website. The institution has on file, multiple inquiries to the NSLDS Customer Support Center in relation to this issue. The Department of Education also posted various Electronic Announcements updating and giving continued guidance to institutions on this issue. The auditors were provided with copies of all of ED’s posting and updates as related to this issue. Nevertheless, during the subsequent months from January 2023 to June 2023 covered in this audit period, the institution was able to complete and report the current enrollment status of students to the NSLDS platform. Actions Taken or Planned: The matter as related to this finding has already been discussed with the Registrar who is responsible for the completion and submission of the Enrollment Reports to the Department of Education To continue to improve on the reporting to student’s enrollment status, the institution would continue to submit its Enrollment Reports monthly instead of every two months as schedule. Status of Corrective Actions on Prior Findings: The issue as related to this finding occurred in the past audit.

View Audit 305178

Finding 395524 (2023-001)

Significant Deficiency 2023

Universidad Teologica Del Caribe, Inc.

PR

Questioned Costs Student Financial Aid Procurement, Suspension & Debarment

Institutional Comments on Findings and Recommendations: Compliance Requirements – Applicable After a Student Begins Attendance: The institution agrees with the auditors on this finding in which there were two (2) cases where the auditors noted that the institution failed to determine that the stud...

Institutional Comments on Findings and Recommendations: Compliance Requirements – Applicable After a Student Begins Attendance: The institution agrees with the auditors on this finding in which there were two (2) cases where the auditors noted that the institution failed to determine that the students withdrew within fourteen (14) days after the student’s last day of attendance. In one (1) of the two (2) cases the Date of Determination was twenty-two (22) days after the Last Day of Attendance and in the second case, the Date of Determination was Three (3) days after the Last Day of Attendance. All funds due to the Department, (for the first case $682.00 of Unsub. Direct Loan funds and in the second case $974.22 of Federal Pell Grant funds), were returned within the forty-five (45) days required timeframe as of the Date of Determination of each case. This process was evidenced to the auditors for their records. Actions Taken or Planned: The institution is fully aware of the Return of Title IV funds (R2T4) reporting requirements and deadlines. The issue related to this finding was identified as a lack in some Faculty notifying student absences within the fourteen (14) day timeframe to process an R2T4 in a timely manner as required. Although this issue was already discussed with them by the Dean of Academic Affairs, an additional follow up meeting would be held to remind them of the importance in monitoring student attendance and notifying student absences to the Registrar office within the required timeframes to fully comply with the R2T4 reporting requirements. Status of Corrective Actions on Prior Findings: The issue as related to this finding occurred in the past audit.

View Audit 305178 Questioned Costs: $1

Finding 395523 (2023-011)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to disbursing loans within aggregate loan limits. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

View Audit 305169

Finding 395516 (2023-010)

Material Weakness 2023

Arkansas Baptist College

AR

Student Financial Aid Subrecipient Monitoring Reporting § 200.512

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administ...

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective immediately and ongoing

View Audit 305169

Finding 395513 (2023-008)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Eligibility

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial ...

Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to over awarding students. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 305169 Questioned Costs: $1

Finding 395511 (2023-007)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Procurement, Suspension & Debarment

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's...

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to students meeting satisfactory academic progress. The College has an SAP appeal committee in place to enforce and abide by the College's policy. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing

View Audit 305169 Questioned Costs: $1

Finding 395510 (2023-006)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Direct...

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid, Chief Financial Officer & V.P. of Academic Affairs Effective: Immediately and ongoing

View Audit 305169 Questioned Costs: $1

Finding 395509 (2023-005)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Regist...

Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Registrar Effective: Immediately and ongoing

View Audit 305169

Finding 395507 (2023-004)

Material Weakness 2023

Arkansas Baptist College

AR

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

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guid...

Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 305169

Finding 395505 (2023-003)

Material Weakness 2023

Arkansas Baptist College

AR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management concurs with this finding. The College will ensure the accuracy of the data that is input into the COD system and the College will work to apply funds appropriately to students' accounts. The College will review and adhere to its practices, policies, and procedures along with federal gu...

Management concurs with this finding. The College will ensure the accuracy of the data that is input into the COD system and the College will work to apply funds appropriately to students' accounts. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to managing the COD system. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 305169

Finding 395503 (2023-002)

Material Weakness 2023

Arkansas Baptist College

AR

Questioned Costs Student Financial Aid Eligibility

Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal gui...

Management concurs with this finding. The College will keep accurate attendance and participation records. The College will calculate R2T4s accurately and will return the funds in a timely manner. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to R2T4 regulations. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing

View Audit 305169 Questioned Costs: $1

Finding 395409 (2023-002)

Significant Deficiency 2023

The Literacy Lab

DC

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.302

Person Responsible: Chief Operating Officer, Deirdre Bagley, will coordinate with the finance team Implementation Date: By August 30, 2024 Management’s response: In response to the recommendation that the Organization properly apply allowed indirect cost rates across its Federal awards, we concur wi...

Person Responsible: Chief Operating Officer, Deirdre Bagley, will coordinate with the finance team Implementation Date: By August 30, 2024 Management’s response: In response to the recommendation that the Organization properly apply allowed indirect cost rates across its Federal awards, we concur with the recommendation and are in the process of creating a single, succinct schedule and the supporting documentation on indirect cost rates and rationale to allow the auditors to easily verify that the costs have been charged appropriately.

View Audit 305163

Finding 395368 (2023-038)

Significant Deficiency 2023

State of Oregon

OR

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2023-038 Department of Early Learning and Care Retain support and improve controls over reporting MANAGEMENT RESPONSE: We agree with this recommendation. DELC will work with the Department of Revenue to substantiate the amount of tax credits used in prior years to meet federal matching and mainte...

2023-038 Department of Early Learning and Care Retain support and improve controls over reporting MANAGEMENT RESPONSE: We agree with this recommendation. DELC will work with the Department of Revenue to substantiate the amount of tax credits used in prior years to meet federal matching and maintenance of effort requirements for FY 20 to FY 22 and ensure this information is retained appropriately outside beyond just email records. In addition, DELC will update processes and procedures to ensure that tax credit amounts used in future reports are properly documented and substantiated by the Department of Revenue. Anticipated Completion Date: October 31, 2024 Contact person: Ali Webb, Operations and Policy Analyst; Connie Range, Fiscal Analyst

View Audit 305129

Finding 395362 (2023-021)

Significant Deficiency 2023

State of Oregon

OR

Matching / Level of Effort / Earmarking § 200.303

2023-021 Oregon Health Authority Implement controls to ensure earmarked expenditures are tracked and compliance achieved MANAGEMENT RESPONSE: We agree with this recommendation. As noted in the audit report, OHA has already taken corrective actions to ensure controls are in place for tracking app...

2023-021 Oregon Health Authority Implement controls to ensure earmarked expenditures are tracked and compliance achieved MANAGEMENT RESPONSE: We agree with this recommendation. As noted in the audit report, OHA has already taken corrective actions to ensure controls are in place for tracking applicable expenditures in SFMA to ensure compliance with federal Earmarking requirements. The Office of Financial Services, OHA Budget Unit, and block grant planners meet at least once a month to review budgeted earmarked requirements and expenditures to ensure compliance. Block grant planners meet at least once a month with the crisis team and children and family team to review required earmark budgets and expenditures. Anticipated Completion Date: June 30, 2023 Contact person: Annabelle Atalig, Budget and Fiscal Manager; Travis Labrum, Grant Accounting Manager

View Audit 305129

Finding 395355 (2023-018)

Significant Deficiency 2023

State of Oregon

OR

Matching / Level of Effort / Earmarking Subrecipient Monitoring Period of Performance § 200.303

2023-018 Oregon Housing and Community Services Ensure grant management report control is performed and documented MANAGEMENT RESPONSE: We agree with this recommendation. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training h...

2023-018 Oregon Housing and Community Services Ensure grant management report control is performed and documented MANAGEMENT RESPONSE: We agree with this recommendation. A dedicated staff resource has been trained and has brought grant reconciliations and reporting current. Additional training has been provided for awareness of the earmarking and obligation requirements as well. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller

View Audit 305129

Finding 395351 (2023-025)

Material Weakness 2023

State of Oregon

OR

Matching / Level of Effort / Earmarking Special Tests & Provisions

2023-025 Department of Human Services Obtain accurate information from the ONE application MANAGEMENT RESPONSE: We agree with this recommendation. The department continues to monitor and review ACF-199 and ACF-209 reports prior to submission. Defects identified through the monitoring and review p...

2023-025 Department of Human Services Obtain accurate information from the ONE application MANAGEMENT RESPONSE: We agree with this recommendation. The department continues to monitor and review ACF-199 and ACF-209 reports prior to submission. Defects identified through the monitoring and review process are logged into TFS and follow the defect management process. ONE/ODHS began SOC audit with an outside vendor at the end of 2023. The department is continuing to work through the items and anticipate completion with this audit by June 30, 2024. The department will share the findings once received if there are any. SOC audits will be done annually from here forward. The Agency provided a cure notice to Deloitte Consulting as the vendor related to the reports in December 2022 and considered the actions cured and removed the notice in July 2023. Quarterly reports sent through the contract have been provided and accepted by ACF. Defect triaging continues to be worked separately, and regular reports to verify changes, additional validations that were put into place, achieve expected quality in correct submission of data on behalf of Oregon from the ONE System. Anticipated Completion Date: December 31, 2024 Contact person: Xochitl Esparza, Program Administration Manager

View Audit 305129

Finding 395345 (2023-040)

Material Weakness 2023

State of Oregon

OR

Matching / Level of Effort / Earmarking § 200.303

2023-040 Oregon Department of Education State did not meet maintenance of effort requirement MANAGEMENT RESPONSE: We agree with this recommendation. The Department of Education agrees with this finding; however, context is critical to understand this requirement. The Maintenance of Effort (MOE) r...

2023-040 Oregon Department of Education State did not meet maintenance of effort requirement MANAGEMENT RESPONSE: We agree with this recommendation. The Department of Education agrees with this finding; however, context is critical to understand this requirement. The Maintenance of Effort (MOE) requirements in The ARP ESSER III legislation are unique. The purpose of the requirement is to ensure that states are not using the federal pandemic funds to replace state funding and then leaving districts with a more substantial “fiscal cliff” when the pandemic funds recede. ODE administers state funding to Oregon districts, but the levels and formulas governing the distribution of the total state funds are determined by the Oregon Legislature and not ODE. While the non-compliance finding implies that Oregon reduced education funding, that is not true. Education funding in Oregon did increase annually, yet not as much as other non-education funding priorities. The United States Department of Education (USDE) formula required to evaluate MOE does not adequately reflect the investment in public education in Oregon, nor does it acknowledge the complexities of Oregon’s state budget or school funding formulas. ODE worked closely with USDE staff monitoring MOE compliance and submitted a request to USED for an MOE waiver on March 14, 2024. We are awaiting a decision from USDE. A response is anticipated by June 2024. Anticipated Completion Date: June 30, 2024 Contact person: Cynthia Stinson, Senior Manager of Federal Investments and Pandemic Renewal Effort

View Audit 305129

Finding 395330 (2023-015)

Material Weakness 2023

State of Oregon

OR

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.311 § 200.313 § 200.317

2023-015 Oregon Housing and Community Services Fully implement controls to ensure subrecipients are in compliance with program requirements MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has hired an outside contractor to complete the requested work. Contractor was not in place in...

2023-015 Oregon Housing and Community Services Fully implement controls to ensure subrecipients are in compliance with program requirements MANAGEMENT RESPONSE: We agree with this recommendation. OHCS has hired an outside contractor to complete the requested work. Contractor was not in place in time to complete action prior to end of audit work, however work will be finalized prior to the end of the current fiscal year. Anticipated Completion Date: June 30, 2024 Contact person: Dean Criscola, Controller

View Audit 305129

Finding 395319 (2023-003)

None 2023

Sistema Universitario Ana G. Mendez, Incorporado

PR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

During November 2023, the Enrollment Reporting Manual was revised. This guide states that the assistant registrar will draw a sample from the of the population to review the data submitted to NSLDS. A retraining session will be coordinated for the assistant registrar, to review the NSLDS certific...

During November 2023, the Enrollment Reporting Manual was revised. This guide states that the assistant registrar will draw a sample from the of the population to review the data submitted to NSLDS. A retraining session will be coordinated for the assistant registrar, to review the NSLDS certification process. This activity will be aligned to the recent updates of the electronic platform.

View Audit 305124

Finding 395270 (2023-063)

Significant Deficiency 2023

State of Rhode Island

RI

Allowable Costs / Cost Principles Subrecipient Monitoring Eligibility

Finding 2023-063 – Corrective Action Plan Each health plan reports TPL recoveries to EOHHS in its quarterly financial report (FDCR). These recoveries are used as a direct offset to medical expenses. As such, claims paid by the plans on behalf of a member with TPL will remain in the EOHHS encounte...

Finding 2023-063 – Corrective Action Plan Each health plan reports TPL recoveries to EOHHS in its quarterly financial report (FDCR). These recoveries are used as a direct offset to medical expenses. As such, claims paid by the plans on behalf of a member with TPL will remain in the EOHHS encounter data warehouse. Health plans do not void claims that have previously been paid to account for any TPL liability. Rather, they seek to recover from the third party any amount owed and report that amount to the state. In each of the last two fiscal years, this reduced medical expenditures by just under $8 million. EOHHS sent the MCOs a full TPL file in July 2023. EOHHS will start the process for a new file in June 2024. Anticipated Completion Date: Ongoing Contact Person: Jeffrey Schmeltz, Chief of Family Health Systems, Executive Office of Health & Human Services jeffery.schmelts@ohhs.ri.gov

View Audit 305097

Finding 395256 (2023-056)

Material Weakness 2023

State of Rhode Island

RI

Questioned Costs Subrecipient Monitoring Eligibility

Finding 2023-056 – Corrective Action Plan Management agrees with the finding. Regulation 4.5.1, RIW approved families are categorically eligible for CCAP services when they have an acceptable need for services related to fulfilling RIW program requirements. The determination of employment plan com...

Finding 2023-056 – Corrective Action Plan Management agrees with the finding. Regulation 4.5.1, RIW approved families are categorically eligible for CCAP services when they have an acceptable need for services related to fulfilling RIW program requirements. The determination of employment plan components including any combination of education and work-related activities in the approved plan are determined by RIW Regulations, section 2.11. The need for services in an RIW CCAP case is based on the employment plan. In situations where an applicant parent does not comply with the RIW employment plan, CCAP services would not be approved. Once CCAP services are approved based on an employment plan for an RIW recipient, the approval is for a 12-month certification period and would not be terminated, per ACF federal requirements, for a subsequent change in employment plan participation or change in income (unless in excess of 85% SMI). It should be noted that in all cases, the decortications were documented in Bridges. CCAP training has also been enhanced in many ways. CCAP training is delivered along with RIW training on a bi-monthly basis for new hires and/or existing ETs The CCAP training module was revised to include topics specific to improper payments. Office of Child Care also holds monthly CCAP office hours for operations staff to connect with program admins, policy and training specialist to answer/troubleshoot questions from the field. Monthly analysis by error type now includes location and worker ID for analysis of more targeted training. DHS also continues to look at system and process improvements. Weekly CCAP theme meetings are ongoing to identify and solution Bridges related incidents. The CCAP Regulations have been reviewed and were opened Q1 2024 for policy updates to streamline and simplify verification processes where possible. Anticipated Completion Date: July 1, 2024 Contact Person: Nicole Chiello, Assistant Director – Office of Child Care, Department of Human Services nicole.chiello@dhs.ri.gov

View Audit 305097 Questioned Costs: $1

Finding 395227 (2023-047)

Material Weakness 2023

State of Rhode Island

RI

Matching / Level of Effort / Earmarking

Finding 2023-047 – Corrective Action Plan RIDE's current subrecipient monitoring policies/procedures are not program specific. RIDE will revise current subrecipient monitoring policies/procedures to include steps to be taken related to reviewing supplement not supplant for all programs during on-s...

Finding 2023-047 – Corrective Action Plan RIDE's current subrecipient monitoring policies/procedures are not program specific. RIDE will revise current subrecipient monitoring policies/procedures to include steps to be taken related to reviewing supplement not supplant for all programs during on-site monitoring. Anticipated Completion Date: December 31, 2024 Contact Person: Mark Dunham, Chief Financial Officer, Department of Elementary & Secondary Education mark.dunham@ride.ri.gov

View Audit 305097

Finding 395218 (2023-041)

Significant Deficiency 2023

State of Rhode Island

RI

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2023-041 – Corrective Action Plan There is no disagreement with the audit finding. The financial aid office has identified the position within the department that is responsible for completing monthly reconciliation or the Direct Lending program. This position has been given the policy an...

Finding 2023-041 – Corrective Action Plan There is no disagreement with the audit finding. The financial aid office has identified the position within the department that is responsible for completing monthly reconciliation or the Direct Lending program. This position has been given the policy and procedures related to reconciliation and has immediately begun following these procedures. This position will also seek out additional resources and trainings to ensure compliance moving forward. The director will support the process by allowing the time for these processes to be done on a monthly basis as well as provide support for future trainings. Anticipated Completion Date: January 2024 Contact Person: Jennifer Burke, Interim Director of Financial Aid, Rhode Island College jburke1@ric.edu

View Audit 305097

Finding 395177 (2023-003)

None 2023

The Shaw University, Inc.

NC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: University Registrar (Charee Ellison), Vice President of Academic Affairs (Dr. Renata Dusenbury) Corrective Action: The University concurs with this finding. This action is completed through a third party service (National Student Clearinghouse) which updates the NSL...

Name of Responsible Individual: University Registrar (Charee Ellison), Vice President of Academic Affairs (Dr. Renata Dusenbury) Corrective Action: The University concurs with this finding. This action is completed through a third party service (National Student Clearinghouse) which updates the NSLDS automatically. As student enrollment changes and awards are adjusted, the Director of Financial Aid updates the Registrar who makes adjustments in NSC and those adjustments are noted in NSLDS. The University Registrar will check behind NSC on a monthly basis to ensure that enrollment dates are correct and have been submitted to NSLDS in a timely manner. Anticipated Completion Date: June 30, 2024

View Audit 305066

Finding 395175 (2023-001)

None 2023

The Shaw University, Inc.

NC

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

Name of Responsible Individual: Director of Financial Aid (Dr. OJ Ifegwu) Vice President of Enrollment Management (Dr. Stacey Sowell) Corrective Action: The University concurs with finding and will monitor internal controls to ensure that all student disbursement data occurs within 15 calendar days...

Name of Responsible Individual: Director of Financial Aid (Dr. OJ Ifegwu) Vice President of Enrollment Management (Dr. Stacey Sowell) Corrective Action: The University concurs with finding and will monitor internal controls to ensure that all student disbursement data occurs within 15 calendar days after payment or the University becomes aware of the need to make an adjustment. Internal controls will be maintained by reporting on a daily basis as disbursements are posted. Anticipated Completion Date: June 30, 2024

View Audit 305066

Corrective Action Plans

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