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US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately...
US Department of Education: Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.063, 84.268, 84.033 Recommendation: CLA recommends OSU OKC and OSUIT review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: OSU OKC: The Director of Financial Aid, Registrar, and Sr Director of Institutional Effectiveness developed a new process on reporting first of term, end of term, updates to enrollment, and processing errors in a timely manner. In addition, the Director of Financial Aid also added a step to the current OSU OKC R2T4 process. Financial Aid counselors will also be checking NSLDS on all students who populate on our R2T4 listing. Monthly, the Director of Financial Aid will select a small population to R2T4 and audit the information reported in NSLDS to ensure the new process is working correctly. OSUIT: OSUIT will shorten the dates for reporting to the NSLC to make sure the NSLC has sufficient time to report to NSLDS. Name(s) of the contact person(s) responsible for corrective action: OSU OKC: Elizabeth Lucas, Director of Financial Aid and Scholarships; Hank Lankford, Registrar; and Nick Irby, Senior Director of Institutional Effectiveness and Accreditation. OSUIT: Matt Short, Director of Financial Aid and Scholarships; and Crystal Palacioz, Registrar. Planned completion date for corrective action plan: OSU OKC: The completion date for the enrollment reporting has been implemented since the end of September 2023. The additional financial aid processes were implemented in October 2023 and will be fully completed by December 1, 2023. OSUIT: December 1, 2023.
Based on our grant agreement with Head Start, Easter Seals DC | MD | VA is required to provide a 20% contribution of total project costs for each annual budget period, unless a waiver has been requested and approved; any combination of actual cash expended, or in-kind contributions, may be used to m...
Based on our grant agreement with Head Start, Easter Seals DC | MD | VA is required to provide a 20% contribution of total project costs for each annual budget period, unless a waiver has been requested and approved; any combination of actual cash expended, or in-kind contributions, may be used to meet the matching requirement. Our organization met the 20% non-federal match requirement for the latest program year (Year 2) for our Early Head Start Program in Washington DC. However, we did not meet the match requirement for Year 5 of our Prince George County program. The mandatory annual waivers associated with our organization’s 20% non-federal share matching contribution requirement for the first four years (2019 - 2022) of the individual award periods ended July 31 of our Prince George’s County Head Start Program grant agreement have been submitted. Likewise, the waiver request for the first year (2022) of the individual award period ended June 30, 2022, for our Washington, DC Head Start Program grant agreement has also been submitted. Per Section 640(b)(1)(5) of the Head Start Act, a waiver request for Year 5 (2023) was submitted alongside the original budget narrative. While the budget was approved, we were notified after the program year ended that a standalone/separate waiver request for Year 5 was required. The outstanding waiver requests remain under review by representatives of The Administration of Families and Children, the agency that oversees the Office of Head Start program. We have maintained a constant dialogue with the Office of Head Start, which administers grant funding and oversight, but have yet to receive formal approval for any of the outstanding waiver submissions. However, we believe that amended waiver requests will be required for some of the program years in which we did not meet our 20% non-federal contribution match in Prince George’s County. In December 2023, we provided the Office of Head Start with additional details related to the organization’s annual expenditures, cash receipts, and non-federal share obligations for the first five years of the Prince George’s County grants. We anticipate that final responses to all five required waiver requests our Prince George’s County Program will be obtained no later than the end of the current grant year (July 31, 2024). We expect the outstanding waiver request for Year 1 of our Washington DC program will be considered and approved by the end of the current grant year (July 31, 2024).
FINDING 2022 – 004: Name of Responsible Individual: Tracy Jenkins, Student Accounts Type of Finding: Authorization for Retaining Credit Balance Criteria: Title IV regulations (34 CFR 668.165(b)) states that an institution must obtain written authorization from a student or parent in order to hold an...
FINDING 2022 – 004: Name of Responsible Individual: Tracy Jenkins, Student Accounts Type of Finding: Authorization for Retaining Credit Balance Criteria: Title IV regulations (34 CFR 668.165(b)) states that an institution must obtain written authorization from a student or parent in order to hold any Title IV program funds that would otherwise be paid directly to the student or parent as a credit balance. Condition: During testing auditors noted one student had a credit balance that was held beyond the end of the loan period without authorization from the student or parent to hold the funds. Corrective Action: During the testing, the audit report noted one student who had a credit balance that was held beyond the end of the loan period without authorization from the student or parent to hold the funds. In response to this finding, 2022-004 Wheeling University Student Accounts Office has added competent staff. Student Accounts has a set calendar for refund dates to coincide with each semester. The first refund distribution happens during the second week of classes for the semester. The exact process is followed for weeks three and four of the semesters. Week seven of the semester is the fourth distribution of refunds, and week nine is the fifth distribution of refund checks. The refund process is completed within seven days of disbursement notification. Anticipated Completion Date: This process was completed in August of 2023 and is an ongoing process.
FINDING 2022 – 003: Repeat of Prior Year Finding 2021-008 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Overaward of Title IV Funds Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct Unsubsidized...
FINDING 2022 – 003: Repeat of Prior Year Finding 2021-008 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Overaward of Title IV Funds Criteria: Title IV regulations (34 CFR 685.203) states in no case may Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan amount exceed the student’s estimated cost of attendance for the period of enrollment for which the loans were intended, less (1) the student’s estimated financial assistance for that period and (2) the borrower’s expected family contribution for that period. Condition: During testing the auditors noted two instances where the University awarded a Direct Unsubsidized loan to a student that caused the student’s financial assistance received to be greater than the student’s cost of attendance. Corrective Action: At the time of these findings, all Wheeling University Financial Aid processing operations were being conducted manually. The high level of complexity commonly associated with financial aid processing creates an environment, especially when conducted in a manual format, that is error-intrinsic. Packaging and awarding for each of the federal student aid programs are currently conducted by using the student information system, Colleague, which allows the FA office to perform these processing operations in a fully automated manner. Proper use of the “auto-packaging” feature provides significant assurance that student awards will not exceed financial need based on Cost of Attendance (COA) and Estimated Family Contribution (EFC). Previous audit findings have noted a general lack of accuracy, organization, and documentation regarding the final figure for the COA, which can result in packaging and over-award errors. As such, the Acting Director of Financial Aid has completely extensively researched and input data into the system with an accurate, fair, and equitable formula for arriving at a COA while meeting student need and, consequently, reducing or eliminating the potential for over-awards. This data was obtained from state and local cost of living figures, input from other similar state schools, and by use of the higher education organization, the College Board. This data is available as a reference for future documentation and review in a shared electronic file. Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.
View Audit 290469 Questioned Costs: $1
FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with ...
FINDING 2022 – 002: Repeat of Prior Year Finding 2021-004 Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Type of Finding: Federal Award Findings and Questioned Costs Criteria: Recipients of federal awards are required to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. Condition: The University did not reconcile its SAS data file to its financial records for all 12 months of the fiscal year. Corrective Action: Wheeling University has implemented several significant corrective actions towards improving the reconciliation requirements for the Pell and Direct Loan Programs. A highly administratively capable staff person has been promoted to Assistant Director and demonstrates a level of financial aid leadership that is appreciated throughout the campus community. This individual has received extensive regulatory and technical training regarding the federal requirements to monthly reconcile cash received from the G5 account with disbursements submitted to the COD System. In addition to confirming the accuracy of monthly reconciliation efforts, this approach allows the FA office to compare internal awarding databases against COD’s database for Pell and Direct Loan awards and identify discrepancies that require further attention. Also, this assists the University to be better prepared to perform efficient and accurate closeout activities at year-end. Previous audit findings showed little evidence of accurate reconciliation efforts. In working with the University IT Department, monthly reconciliation files are now housed in a shared electronic file system, easily retrieved for review, and are confirmed for accuracy by the acting Director of Financial Aide each month. Anticipated Completion Date: This process was completed in March of 2023 and is ongoing.
FINDING 2022 – 006: Type of Finding: Significant Deficiency-Return of Title IV Funds Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the...
FINDING 2022 – 006: Type of Finding: Significant Deficiency-Return of Title IV Funds Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: Title IV regulations (34 CFR 668.22) require the University to return the unearned portion of grants or loans to the student based the calculated percent completed by the student. Condition: Calculations of return of funds for certain students selected for testing were not completed and therefore refunds were not made. Corrective Action: Audit results identify several Wheeling University Financial Aid R2T4 calculations that were found to be incomplete, inaccurate, or not completed within an acceptable time frame as required by regulations. The apparent cause of these findings was a lack of administrative capability, staff turnover, and a general lack of a systematic process for completing accurate R2T4 calculations. Since these findings were first noted, the Wheeling University Financial Aid Office has added competent staff and has provided sufficient training and supervised experience to ensure R2T4 calculations are completed within the regulatory guidelines. The acting Director of Financial Aid has taken steps to ensure to inform the campus community of the Department’s philosophy of an “institutional responsibility” regarding regulatory compliance with Title IV programs, and this is particularly true in the matter of student FA eligibility with enrollment, attendance, and withdrawal. As such, the acting Director of Financial Aid has worked closely with the University Registrar to ensure there is a clear understanding that if a recipient of Title IV grant or loan funds withdraws from the University after beginning attendance, the FA Office must perform an R2T4 calculation to determine the amount of Title IV assistance earned by the student. Since withdrawal information is critical to R2T4 calculations, a Withdrawal Report has been developed to better capture withdrawal data. This report is updated and reviewed by the FA Director (three times per week) to confirm the accuracy of such data. In addition, all R2T4 calculations are completed on the University's internal software (Colleague) rather than DOE software and follow an updated, more clearly defined R2T4 policy. Anticipated Completion Date: This process was completed September of 2023 and is ongoing.
FINDING 2022 – 005: Repeat of Prior Year Finding 2021-003 Type of Finding: Material Weakness-Enrollment Reporting Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: An institution is required to update students’ changes in status on the National Studen...
FINDING 2022 – 005: Repeat of Prior Year Finding 2021-003 Type of Finding: Material Weakness-Enrollment Reporting Name of Responsible Individual: Joyce Lubeck-Sonenberg, Acting Director of Financial Aid Criteria: An institution is required to update students’ changes in status on the National Student Loans Data System (NSLDS) website within 30 days of the date the institution becomes aware of the change in enrollment status for students that graduate, withdraw, or have an increase or decrease in attendance during the fiscal year (34 CFR 685.309). Condition: For certain students selected for testing who graduated or withdrew during the year, the University did not submit an appropriate and/or timely status change notification to the NSLDS website. A group of graduated students were erroneously reported as ‘withdrawn’ from the University. Corrective Action: Audit results identify several Wheeling University Enrollment Reports that were found to be incomplete, inaccurate, or not completed within an acceptable time frame as required by regulations. In response to finding 2022-005, Wheeling University has implemented several significant corrective actions towards improving Enrollment Reporting. The apparent cause of these findings was a lack of administrative capability, staff turnover, and a general lack of a systematic process for completing accurate Enrollment Reports to the National Student Clearing House (NSC) and National Student Loan Data System (NSLDS). Since these findings were first noted, the Wheeling University Registration Office and Financial Aid Office have added competent staff and have provided sufficient training and experience to ensure Enrollment Reports are completed within the regulatory guidelines. The Vice President of Enrollment has worked closely with the Financial Aid Office and the Registration Office to ensure there is a clear understanding of who reports to the National Student Clearing House and who is responsible for monitoring NSLDS. There are also weekly meetings between the Business Office, Registration, and Financial Aid to ensure all reporting is correct and completed in a timely manner. Anticipated Completion Date: A new process has been in place Since October 2023 and is ongoing.
2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disa...
2023-002 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: MACC is an attendance taking institution and our regular practice requires review of attendance records two to three times per week. When the Financial Aid Office discovers students have withdrawn from classes, we review and calculate an R2T4 when required - usually within 1-5 days from the date it is discovered. This finding of a "late return" is due to a faculty member dropping a student outside of the dates required by our attendance policy. I would like to note that the R2T4 was performed timely and accurately as soon as the drop was identified. Action taken in response to finding: The issue was reported to the President, Vice Presidents, and Deans; as a result, the faculty were addressed and reminded of the importance to comply with the college's attendance policy. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: Our Vice President for Instruction will provide reminders of our policy with our faculty each semester. In the event that a faculty member does not comply with the attendance policy, their Dean will take disciplinary action.
2023-001 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with...
2023-001 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.063 Recommendation: We recommend that the student financial aid department work to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation of disagreement with audit finding: As a standard, regular practice, communicates disbursement information for Federal Pell and Federal loans to COD no less than once per week; therefore, we believe we have an adequate way to report disbursements to COD within 15 days of the disbursement date. MACC transitioned to new financial aid processing software (Jenzabar Financial Aid - JFA) in summer 2022 while other areas of the college were still using the "old" system (Jenzabar CX). We experienced a glitch during the transition in which the files did not update as expected, we worked with our software vendor to correct the issue. Below is the timeline of action taken:This finding pertains to one student with Sub and Unsub Loans. We posted aid and sent the original batch on Friday, 07/15/2022; we discovered the issue on Wednesday, 07/20/2022, and reached out to Jenzabar immediately; we followed up with Jenzabar on Thursday, 07/28/2022 because the records were not updated; the records were updated on Monday, August 1. Action taken in response to finding: MACC continues to submit disbursement information at least once per week and review student details for posting accuracy. We took the necessary steps to fix the issue. Name(s) of the contact person(s) responsible for corrective action: Amy Hager Planned completion date for corrective action plan: We believe this finding was an anomaly due to the system conversion. We have no evidence of this happening since.
2023-003 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accuratel...
2023-003 US Department of Education Student Financial Assistance Cluster - Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding, but we offer the following explanation: Identification of Errors and Corrections to New SIS: • Conversion to a new SIS (Jenzabar - Jl) was effective November 2022, and forced subsequent Fall 2022 NSC Enrollment Transmittal Files to be created in the new system mid-term. The concern of enrollment report timing was brought to the vendor multiple times before the transition. However, due to scheduling limitations on the vendor's end, the transition to the new system had to be completed mid-term. • In late May/early June we began end of term processing and reconciliations, and we identified that student status changes were not properly pulling the correct enrollment status information through the vendor's enrollment report creation process. • Support tickets were sent to the vendor immediately to address the problems with the system process that creates NSC Transmittal Files. • System configuration changes were made as recommended by the vendor to properly update enrollment status changes. • Through the investigation of these configuration changes, additional system errors were identified that were not allowing some enrolled students to be properly pulled to the enrollment files. • Support engagements continued with the vendor throughout July and August to identify and correct the system configuration to correctly pull enrolled students into the NSC Transmittal File. This was completed by the end of summer term, and the final summer enrollment file contained the correct number of students enrolled with the correct final enrollment status. • Internal validation reports were created and executed to ensure that correct student data was transmitted on the Fall first of Term reports. We believe this transmission contained the correct number of students and the correct status. These internal validation reports will be conducted prior to all NSC submissions. Creation of new/additional reports will be conducted as necessary. • We have been able to verify that the Fall 2023 subsequent term enrollment file did contain accurate status change information, and this issue is now resolved. • By correcting status change configurations, we have also identified that program begin dates converted from the old SIS to the new SIS were incorrectly mapped. • We are currently in the process of identifying the ID#s with incorrect program begin dates and making manual updates to the students' record in the new SIS environment. The vendor has not provided a clear path to programmatically correct this in bulk, so this record validation is being completed one-by-one manually. We project to have this completed for currently enrolled students by the final fall 2023 enrollment submission. Correcting previously submitted data: • We reached out to our Data Analyst, Elizabeth Fennessy, with the National Student Clearinghouse, to begin working on a corrective action for the missing status change data. • Elizabeth consulted with the NSC Audit Resource Team, and the following plan was recommended to MACC: • For students Less Than Half Time Spring 2023 or Withdrawn Spring 2023 that re-enrolled Summer 2023, these would be a manual update in NSLDS for Title IV students in these scenarios using NSLDS site 'Enrollment History Update.' • Later in Clearinghouse, the same update can be reflected using Clearinghouse site 'Student Look-Up' to bring the record current with updated enrollment reflected Spring 2023. By updating NSLDS first, that will avoid an NSLDS error "certification date out of sync" (error code 32). • MACC prepared reports to retrieve students meeting the criteria identified above. • These students' enrollment statuses for Spring 2023 and Summer 2023 have been manually updated in NSLDS Enrollment History Update and in NSC Student Look-up to bring these enrollment statuses up to date; this has been a long and time-consuming process. • We are also currently working on reports to identify students that were enrolled in spring 2023 but missed when the NSC Enrollment Transmittal File was created. We believe that students missed in Summer 2023 have been brought up to date through the submission of the corrected final Summer 2023 Enrollment File (to include students that were also enrolled in Spring 2023). Any student that was inadvertently excluded from the Spring 2023 and has not been brought up to date through subsequent corrected submissions, will be manually corrected through NSC Student Look-Up, and NSLDS Enrollment History Update if necessary. • We also reached out to l<athy Feith, Branch Chief, l<C School Participation Division, Federal Student Aid, U.S. Department of Education; she is aware of our issues. She recommended making enrollment changes directly in NSLDS for students who withdrew. Action taken in response to finding: The following is our Corrective Action Plan. • The Registrar will review data in J1 and submit enrollment records to NSC each month. o The Registrar will also work with the Director of Administrative Computing to ensure program information and other vital data are reported correctly. o MACC will continue to work with Jenzabar for a solution for reporting last dates of attendance for students who are withdrawn from all classes. • After the enrollment file is accepted by NSC, 20 randomly selected students will be verified for accuracy. • The selection will be made by the Director of FA and/or Registrar. • The selection will include students who have withdrawn from all classes and had an R2T4 calculation performed. • The Registrar, or designee, will review the data in NSC. • The Associate Director of Financial Aid, or designee, will review the data in NSLDS. • Discrepancies will be addressed between the Registrar and Financial Aid Offices immediately; and will utilize the Director of Administrative Computing to assist with configuration changes and data clean-up. • The records will be maintained in a designated Teams folder. Name(s) of the contact person(s) responsible for corrective action: Amy Hager and Amy See (Registrar). Planned completion date for corrective action plan: We expect the plan will be an ongoing effort to ensure compliance.
Finding 369039 (2023-003)
Significant Deficiency 2023
Federal Program Title: Student Financial Aid Cluster (SFA), COD posting and reconciling. ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dat...
Federal Program Title: Student Financial Aid Cluster (SFA), COD posting and reconciling. ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: We noted 1 out of 40 COD disbursements tested, were not reported within the required 15 days to COD. Context: 1 of the 40 COD disbursements had applied dates greater than 15 days from the disbursement dates. Recommendation: We recommend that the student financial aid department works to ensure disbursements are reported to COD within 15 days of the disbursement date. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Students identified in the weekly reconciliation that have not posted to COD will be highlighted. In the subsequent reconciliation if student still has not been posted in COD the Financial Aid Director will manually post the student to COD as well as fix any errors so that if can be posted. Name(s) of the contact person(s) responsible for corrective action: Mattie Keys, mattie.keys@connorsstate.edu Planned completion date for corrective action plan: Dec 31, 2023
Finding 369035 (2023-002)
Significant Deficiency 2023
Federal Program Title: Student Financial Aid Cluster (SFA), 60-day status reporting ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 1...
Federal Program Title: Student Financial Aid Cluster (SFA), 60-day status reporting ALN Number: 84.007, 84.033, 84.063, 84.268 Condition: Fifteen exceptions were observed during Enrollment Reporting testing. The fifteen exceptions were reported beyond the sixty-day allowable timeframe. Context: 15 of the 40 enrollment changes were reported to NSLDS greater than 60 days from the change Recommendation: CLA recommends implementing a formal review process that involves footing the report to verify clerical accuracy and detect errors during the preparation of the report. Explanation if disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: At the end of each semester a listing of all graduates will be given to the Financial Aid Office from the Registrar. Financial Aid will then go into NSLDS to manually update graduates status. This process will be done in conjunction with the submittion of graduates to the National Clearinghouse by the Registrar. Name(s) of the contact person(s) responsible for corrective action: Mattie Keys, mattie.keys@connorsstate.edu Planned completion date for corrective action plan: Dec 31, 2023
2023-001 - U.S. Department of Education Student Financial Assistance Cluster- Special Tests and Provisions: Return of Title IV Funds The Financial Aid staff will immediately implement a training and approval process including the following steps: 1. Financial Aid staff will complete online training...
2023-001 - U.S. Department of Education Student Financial Assistance Cluster- Special Tests and Provisions: Return of Title IV Funds The Financial Aid staff will immediately implement a training and approval process including the following steps: 1. Financial Aid staff will complete online training modules concerning the Return to Title IV (R2T4) calculation worksheet. 2. Financial Aid staff will conduct a full research and review of the current USDOE regulations concerning Withdrawals and the Return of Title IV Funds according to the Federal Student Aid Handbook, Volume 5 - Withdrawals and the Return of Title IV Funds. 3. Financial Aid staff will be required to submit the R2T4 calculation worksheet for review and approval by the Financial Aid Director or executive administrator of Financial Aid prior to submitting the worksheet in COD and before requesting that the Chief Financial Officer submits a return of the funds. Implementation ohhis training and approval process will begin no later than November 1, 2023, and be completed no later than January 1, 2024.
Recommendation: The Organization set up a schedule and tracking system in order to contact the City and OHCS in advance of the due date of inspections in order to allow the City and OHCS sufficient time to complete the inspections timely. Action: The Organization has created a tracking system tha...
Recommendation: The Organization set up a schedule and tracking system in order to contact the City and OHCS in advance of the due date of inspections in order to allow the City and OHCS sufficient time to complete the inspections timely. Action: The Organization has created a tracking system that identifies when the last inspection was completed and when the next inspection should be due based on the number of units at each complex. We are already scheduling inspections with the City for each complex under their jurisdiction. OHCS completed their inspection this past October.
The following was noted during the audit of Federal programs in accordance with UMB Uniform Guidance. Management proposes the following Corrective Action Plan: Finding 2023-0001: Suspension and Debarment Check - Management’s View - The University agrees with this finding and acknowledges the import...
The following was noted during the audit of Federal programs in accordance with UMB Uniform Guidance. Management proposes the following Corrective Action Plan: Finding 2023-0001: Suspension and Debarment Check - Management’s View - The University agrees with this finding and acknowledges the importance of maintaining evidence of review for suspension and debarment of vendors. Vanderbilt takes findings seriously and is committed to ensuring that all necessary checks and verifications are conducted in accordance with the federal regulations and our internal controls. Vanderbilt Supplier Records was formerly relying on manual processes to input and support the review of suppliers. Corrective Action Plan - As a corrective measure, Vanderbilt engaged with GIACT Systems to enhance existing controls by implementing an automated control that facilitates Office of Foreign Assets Control (OFAC) screening via an Application Programming Interface (API). This measure was put in place to ensure that all necessary suspension and debarment checks are conducted timely and accurately for every vendor onboarded. The new automated control via GIACT’s API ensures a more streamlined and reliable process for performing suspension and debarment checks. This automation not only checks the status of vendors but also maintains a detailed log of each check performed, thus addressing the documentation inadequacies noted in the audit finding. This enhancement ensures Vanderbilt is in compliance with 2 CFR section 180.995 and the respective agency adopting regulations. Vanderbilt is undergoing a reconciliation of all active federal suppliers to ensure OFAC screening is complete. Additionally, Vanderbilt has reiterated to all control owners the importance of adherence to internal controls and policies regarding suspension and debarment checks. Vanderbilt has also scheduled routine reviews to ensure that these checks are being performed for all vendors. Vanderbilt will continue to monitor and improve our processes to ensure full compliance with federal requirements and our internal policies. For follow-up questions and information, please contact Dalana Robertson, Associate Vice Chancellor for Finance and Controller.
Finding number 2023-001 – Special Tests and Provisions-Enrollment Reporting-Significant Deficiency Over Internal Controls Over Compliance Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corrective action: The corrective action wa...
Finding number 2023-001 – Special Tests and Provisions-Enrollment Reporting-Significant Deficiency Over Internal Controls Over Compliance Contact person responsible for corrective action: Sue Gosney, Chief Financial Officer, (213) 356-5330 Expected date of corrective action: The corrective action was implemented in December 2023. The school's management agrees with the finding and has implemented procedure whereby changes in enrollment status reported to the National Student Clearinghouse will be sample reviewed by the Registrar within NSLDS five business days following the reporting date to ensure the accuracy of the information. As an additional layer, the Financial Aid Manager will also calendar a review reminder. Permanent address changes will be reported on a six-week cycle after the add/drop period each term. Address changes will also be sample reviewed to ensure accuracy within NSLDS.
Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are b...
Department of Education 2023-002 Student Financial Assistance – Assistance Listing No. Various Recommendation: We recommend the University reevaluate 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 auditfinding. Action taken in response to finding: Auditors identified five students where the change in enrollment status was not reported in a timely manner. It was noted that we identified the status changes while there was a cybersecurity breach within the file transfer system used by the National Student Clearinghouse (NSC), our third-party servicer. As a result, our reporting was delayed. We received notice of the incident from the NSC on June 16, 2023. Our next planned transmission was scheduled for June 28. We postponed our regular reporting schedule for one week while we reset our secure FTP password with NSC, initialized our account in their updated system, and while our ITS security officer evaluated the risk. We ended up submitting the file to the NSC on July 5. As a result of this incident, we remain vigilant for external factors that may impact our reporting schedule. We will address them as quickly as possible to avoid reporting delays. Names of the contact persons responsible for corrective action: Gwenn Sherburne, Registrar Planned completion date for corrective action plan: By first reporting date for 2023-2024 academic year in early September 2023.
CORRECTIVE ACTION PLAN December 18, 2023 The Kutztown Area School District respectfully submits the following corrective action plan for the fiscal year ended June 30, 2023. Name and address of Independent Public Auditing Firm: Herbein & Company 2763 Century Blvd. Reading, PA 19610 Audit Period...
CORRECTIVE ACTION PLAN December 18, 2023 The Kutztown Area School District respectfully submits the following corrective action plan for the fiscal year ended June 30, 2023. Name and address of Independent Public Auditing Firm: Herbein & Company 2763 Century Blvd. Reading, PA 19610 Audit Period: July 1, 2022 - June 30, 2023 The findings from the June 30, 2023 schedule of findings are discussed below. Section III - Federal Awards Findings and Questioned Costs 2023-001 EQUIPMENT AND REAL PROPERTY MANAGEMENT - SIGNIFICANT DEFICIENCY Federal Program Education Stabilization Fund ALN 84.425D - COVID-19 - Elementary Secondary School Emergency Relief Fund (ESSER II), contract #200-210215 ALN 84.425U - COVID-19 - Elementary Secondary School Emergency Relief Fund (ESSER III), contract #223-210215 Criteria In accordance with Uniform Guidance Title 2 CFR 200.313, a non-Federal entity may not encumber equipment without prior approval of the Federal awarding agency. Condition The District charged costs for server and firewall purchases which met the definitions and thresholds requiring prior written approval, however, the District’s grant applications did not include these purchases as part of the budget submitted and they did not obtain prior approval through other means. Cause The District revised their original plan for spending of the ESSER funds and there was oversight in completing a revised budget to reflect the changes which included purchases that required pre-approval. Information regarding the pre-approval requirement for equipment purchases was not properly communicated between federal program leadership and the business office. Controls in place over equipment and real property management did not detect the pre-approval requirement prior to encumbering the cost using federal funds. Effect Costs encumbered without required prior approval are unallowable. The District subsequently communicated with the Pennsylvania Department of Education (PDE), the passthrough agency, and submitted budget revisions including these costs which were approved by PDE and deemed allowable. Questioned Costs None. Context We examined all equipment purchases charged to the Education Stabilization Fund during the year. Two of the three invoices examined had purchases totaling $110,986 which required pre-approval. Pre-approval was not obtained for either purchase; however, they were subsequently approved via interim budget revisions. Repeat Finding No. Recommendation We recommend the District revisit procedures for reviewing program guidelines and requirements prior to approving and incurring costs for equipment and real property from federal funding sources. Action Plan The District had made revisions to the original ESSER budgets to utilize ESSER funds to include upgrades technology infrastructure. The magnitude of these expenditures created an unrecognized need for preapproval of capitalized equipment from the Federal award agency. While all other purchasing requirements were properly documented, the District recognized the need for the additional level of approval subsequent to the purchase of the equipment. The necessary ESSER prior approval for the capital expenditures was applied for and awarded by the Federal awarding agency. Additionally, internal processes have been added to purchasing with grant funds. Any future changes to grant budgets will be requested prior to purchasing. Anticipated Completion Date Action plan fully implemented as of report date. If the Department of Education has questions regarding this plan, please contact Elizabeth A. Siteman at 610-683-7361, extension 5526 or via email at esiteman@kasd.org. Sincerely, Elizabeth A. Siteman Business Administrator
We concur with the condition noted above. Management believes that the controls in place are appropriately designed to prevent and or detect errors. This instance was isolated and resulted from a coding error related to incorrectly keying the accounting string into our accounting system, which went ...
We concur with the condition noted above. Management believes that the controls in place are appropriately designed to prevent and or detect errors. This instance was isolated and resulted from a coding error related to incorrectly keying the accounting string into our accounting system, which went undetected. Management reassessed the controls over reporting and compliance with laws and regulations. The following steps have been taken to strengthen controls: • Implement enhanced management tools i.e. ERP and shared weekly ledger reports • Staff training in accounts payable to identify and correct errors • Develop operating procedures requiring weekly budget monitoring and updates for program managers
Finding 2023-001 - Special Tests and Provisions – Gramm-Leach-Bliley Act Responsible Individuals – Director of Computer Services and Vice President for Finance & Risk Management. Finding Summary: During testing of Gramm-Leach-Bliley Act and inquiry with management, it was determined that the Univ...
Finding 2023-001 - Special Tests and Provisions – Gramm-Leach-Bliley Act Responsible Individuals – Director of Computer Services and Vice President for Finance & Risk Management. Finding Summary: During testing of Gramm-Leach-Bliley Act and inquiry with management, it was determined that the University does not have a written comprehensive information security program in place. Corrective Action Planned: Dordt will be working with an external organization familiar with the policy requirements of the Gramm-Leach-Bliley Act to take existing procedures and incorporate them into a formal written information security policy that addresses the key areas of the Gramm-Leach-Bliley Act. Anticipated Completion Date: June 30, 2024.
The College will implement procedures to ensure accurate, timely, and complete data is submitted. As an added layer of data validation and verification, the reports required for the Clearinghouse and generated through the college’s student information system will be converted to Excel format (from N...
The College will implement procedures to ensure accurate, timely, and complete data is submitted. As an added layer of data validation and verification, the reports required for the Clearinghouse and generated through the college’s student information system will be converted to Excel format (from Notepad) with the help of the Institutional Research office to ensure that data meets the criteria required by the clearinghouse and is free of errors. The responsibility to ensure that data submitted to the National Clearinghouse and NSLDS remains with the Registrar’s office at CCSJ. The Registrar’s office at CCSJ will review data for accuracy, timeliness, and completeness before uploading to the FTP Clearinghouse site. Furthermore, the Director of Student Financial Services has been added as a secondary administrator to the college’s FTP clearinghouse account in which he and the Registrar will receive alerts generated through the Clearinghouse when reports have been uploaded to the site. The Registrar is the primary party responsible for clearing alerts, but the Director of Student Financial Services will verify that the alerts have been cleared. Responsible officers: Marlena Avalos, Assistant Vice President of Academic Affairs (mavalos@ccsj.edu); Derek Shouba, Vice President of Academic Affairs Estimated completion date: March 31, 2024
Planned Corrective Action: The College has completed a comprehensive risk assessment performed by a third party, OculusIT. The College is actively working on creating a comprehensive information security program based on the assessment. CCSJ is also actively soliciting bids from vendors to perform r...
Planned Corrective Action: The College has completed a comprehensive risk assessment performed by a third party, OculusIT. The College is actively working on creating a comprehensive information security program based on the assessment. CCSJ is also actively soliciting bids from vendors to perform required tests, such as penetration tests and vulnerability assessments to test the safeguards that are in place. CCSJ has named a qualified individual, Tony Kwintera - Director of IT Operations, to oversee the information security program. We are also reaching out to our 3rd party partners to ensure that their data privacy safeguards align with the requirements of the GLBA. Responsible officers: Tony Kwintera, Director of IT Operations (tkwintera@ccsj.edu); Lynn Miskus, Vice President of Business and Finance Estimated completion date: June 15, 2024
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2023 Award Year; U.S. Department of Education Criteria or Specific Requirement ...
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2023 Award Year; U.S. Department of Education Criteria or Specific Requirement Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves-of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Condition Of the 40 students selected for enrollment reporting testing, three students were reported to NSLDS outside the maximum 60-day window. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will continue to remain vigilant in its oversight over timely communication of enrollment reporting detail to NSC and from NSC to NSLDS, utilizing enhanced exception reporting and a structured process to identify any discrepancies in the data. Names of Contact Persons Responsible for Corrective Action: Nadira Dookharan, Registrar and Anne-Marie Caruso, Associate Vice President, Student Financial Services Anticipated Completion Date: November 30, 2023
Finding – Eligibility – Federal Direct Student Loan Program, Assistance Listing Number 84.268 and Federal Pell Grant Program, Assistance Listing Number 84.063; June 30, 2023 Award Year; U.S. Department of Education Criteria or Specific Requirement ...
Finding – Eligibility – Federal Direct Student Loan Program, Assistance Listing Number 84.268 and Federal Pell Grant Program, Assistance Listing Number 84.063; June 30, 2023 Award Year; U.S. Department of Education Criteria or Specific Requirement The amount of a student's Pell Grant for an academic year is based upon the payment and disbursement schedules published by the Secretary for each award year (34 CFR Section 690.62(a)).The annual maximum loan amount an undergraduate student may receive must be prorated when the borrower is enrolled in a program that is shorter than a full academic year; or enrolled in a program that is one academic year or more in length, but is in a remaining period of study that is shorter than a full academic year. (2022 - 2023 Student Financial Aid Bank Book, Volume 3, Chapter 5, 34 CFR 685.203(a),(b),(c)) Condition Of the 40 students selected for eligibility testing, two students were incorrectly awarded student financial assistance; one student was incorrectly under-awarded a Pell Grant and the other student was over-awarded a Direct Loan. This was not a statistically valid sample. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University will implement regular periodic quality control checks, utilizing enhanced reporting and dedicated staff resources to ensure student aid is being appropriately calculated and awarded based upon relevant student enrollment and financial information. Names of Contact Persons Responsible for Corrective Action: Anne-Marie Caruso, Associate Vice President, Student Financial Services Anticipated Completion Date: November 30, 2023
View Audit 289972 Questioned Costs: $1
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures to ensure file documentation would identify stud...
FINDING 2023-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures to ensure file documentation would identify students in the return funds population. Plan South Suburban College has already established a control process to assist with remaining in compliance as stated in the Single Audit Report Finding 2023-003 Recommendation section. Previously, South Suburban College Financial Aid Department used Business Objects reports to retrieve the college Return of Title IV funding (R2T4) population, it was found that the reporting process was insufficient, therefore the Director of Financial Aid decided to develop an R2T4 tracking process to maintain accurate return of funds calculations. The R2T4 student tracking process is reviewed by the Financial Aid Coordinator and verified by the Financial Aid Manager every week. The Director of Financial Aid will continue to work with South Suburban College Information Technology Department to enhance the retrieval of the Return of Title IV funding student populations reporting process through Ellucian Colleague per 34 CFR 668.22(a)(1) through (a)(5). *This corrective plan has been implemented. Anticipated Date of Completion 1/24/24 Name of Contact Person Avianca Taylor, MBA
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