Corrective Action Plans

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Saint Mary's believes that the switch to J1 and upcoming J1 software patch should solve the reporting issues. We anticipate that all students will be submitted to the Clearinghouse correctly, and will set up ad hoc reports to verify no students are missed. As for the NSC reporting correctly to NSLDS...
Saint Mary's believes that the switch to J1 and upcoming J1 software patch should solve the reporting issues. We anticipate that all students will be submitted to the Clearinghouse correctly, and will set up ad hoc reports to verify no students are missed. As for the NSC reporting correctly to NSLDS, we anticipate that the two entities have resolved the issues that they were having in communicating with each other. The Registrar's Office will ask the Financial Aid office to verify that students are being reported to NSLDS correctly. The Registrar's Office does not have access to NSLDS, but the prior Financial Aid Director did, so the current one should as well.
Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not real...
Common Origination and Disbursement (C OD) Reporting Planned Corrective Action: We are working to put a double check process in place, and to understand which step in the internal aid process has the opportunity to ensure this date exactly matches the COD disbursement date. The team had not realized that the date must match exactly. We have engaged an outside vendor to provide knowledgeable staff augmentation to help us improve our processes and the timeliness of our disbursing of Title IV funds. Person Responsible for Corrective Action Plan: Cathy Morgan, Director of Student Financial Services Anticipated Date of Completion: March 1, 2024
The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full time on campus Director of Financial Aid, which has stabilized the department staffing. ...
The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full time on campus Director of Financial Aid, which has stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward.
The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full-time on campus Director of Financial Aid, which has stabilized the department staffing. ...
The University experienced staffing turnover in the financial aid department during the 2022-2023 aid year, resulting in certain established processes to go unfollowed. In March 2023, the University hired a full-time on campus Director of Financial Aid, which has stabilized the department staffing. The Director has established clear roles and responsibilities so that established processes are not missed going forward. Additionally, the University has reviewed all procedures for identifying official and unofficial withdrawals, adding a new requirement for all faculty members to include a last date of attendance for all unsatisfactory grades input into our student information system. Additionally, job duties have been reallocated to ensure calculations on official and unofficial withdrawals and exit counseling communications are done on a timely basis going forward.
There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.
There is no disagreement with the audit finding. Corrections for this finding started in January 2023. Initial months selected were prior to that date. Additional months were provided, tested and complied. NCU will continue to do our monthly reconciliations in the same manner.
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS...
There is no disagreement with the finding. All program lengths have been corrected in our NSLDS reporting cycle. Unfortunately, the implementation went beyond the May 31, 2023, fiscal year. During a recent internal audit of 20 students we can now see the published length correctly reporting in NSLDS for all investigated students.
There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to...
There is no disagreement with the audit finding. We have diligently reviewed our procedures and implemented robust measures to ensure strict adherence to the regulations governing Return of Title IV Funds. Our efforts have focused on establishing comprehensive double checks throughout the process to mitigate any potential errors or oversights. This includes enhanced annual training, dual verification process - every Return of Title IV fund calculation must now be calculated first by our Financial Aid Data and Reporting Analyst and then re-calculated and reviewed by the Executive Director of One Stop. We now have a robust documentation process for each return and prior to the end of the fiscal implemented internal audits of all withdrawn students. We are confident these measures will maintain compliance and ensure accuracy.
Christopher Cartmill, Director of Financial Aid, Telephone 716-375-7888. We are in agreement with the auditors' recommendation to ensure personnel involved with R2T4 calculations receive appropriate training and update the policies and procedures manaual to require formal review and approval of all ...
Christopher Cartmill, Director of Financial Aid, Telephone 716-375-7888. We are in agreement with the auditors' recommendation to ensure personnel involved with R2T4 calculations receive appropriate training and update the policies and procedures manaual to require formal review and approval of all R2T4 calculations. We have developed additional procedures to ensure institutionally scheduled breaks are being considered in determining a student's percentage of Title IV aid earned. The procedures include participation in training webinars and updates to the policies and procedures manual with detailed instructions on how to calculate the number of days in the semester and formal review and approval of all R2T4 calculations. The procedures also include secondary check by the Director or designate, of entered dates in the calculation set up. The training and updated policies and procedures were completed on September 14, 2023, effective with the Fall 2023 term and forward.
Corrective Action Plan: The College acknowledges that the noted three off-cycle disbursements did not meet the notification requirement. The College has evaluated its current procedures for releasing its financial aid notifications and identified system improvements that will result in notifications...
Corrective Action Plan: The College acknowledges that the noted three off-cycle disbursements did not meet the notification requirement. The College has evaluated its current procedures for releasing its financial aid notifications and identified system improvements that will result in notifications being sent prior to the disbursements being processed to ensure all requirements for this program are met. Timeline for Implementation of Corrective Action Plan: These process and system updates will be implemented before the end of fiscal year 2024.
FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing...
FINDING 2023-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by the Assistant Superintendent without an oversight or review process in place to prevent, or detect and correct, errors. Furthermore, the reported data on two of the reports could not be traced back to records that accumulate or summarize the data; therefore, the accuracy and completeness of the reports could not be verified. Contact Person Responsible for Corrective Action: Jim Diagostino, Superintendent, and Lori Bennett, Treasurer Contact Phone Number: 317-539-9200 Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: The Superintendent, or designee, will prepare the annual data reports to be reported to the IDOE by using records that accumulate or summarize the data. Prior to the submission of the reports, the Treasurer will review the records and annual data report. The Treasurer will initial and date a hard copy of the report to ensure accuracy and completeness. Anticipated Completion Date: March 31, 2024
The Office of Student Financial Aid will update their procedures to verify the proper aid is packaged and awarded based on the student status.
The Office of Student Financial Aid will update their procedures to verify the proper aid is packaged and awarded based on the student status.
2023-004 Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no d...
2023-004 Student Financial Assistance Cluster – Assistance Listing No. 84.038 Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With one year until the program is fully sunset, we will continue to manage and safeguard the promissory notes that we have in our possession. We do not disagree that some MPNs were not able to be found, but with only 90 accounts remaining, we are confident that we have the grand majority of MPN’s needed to close the program in the near future. Name(s) of the contact person(s) responsible for corrective action: Michael Johnson, Controller Planned completion date for corrective action plan: March 1, 2024
2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit ...
2023-002 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely 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: The Bethel University Registrar is responsible for ensuring timely and accurate reporting to NSLD via the National Student Clearinghouse. Cheryl Fisk was appointed to serve as University Registrar on August 1, 2022. While new to Bethel, she is not new to Clearinghouse reporting. She assumed the oversight of the Clearinghouse reporting and is working to ensure timely, accurate submissions. • Bethel reports student enrollment to NSLDS via the National Student Clearinghouse • Currently, the people involved in the process include: o Data Management Team: Ana Ortiz, Data Coordinator o Registrar Staff: Cheryl Fisk, University Registrar o Information Technology Service Staff: Kurt Jarvi, Systems Analyst Based on the previous audit, adjustments were made to the timing of the Clearinghouse enrollment submissions. This has been accomplished with enrollment being reported every month on the same date to enable automated submissions. As we tried to systematize graduation reporting, we encountered multiple technical issues. These issues involved both Information Technology and the Clearinghouse, which resulted in a delay in the reporting of graduates from May through August 2023. Additional training has been provided by the Clearinghouse and other sources which have been viewed by those involved in Clearinghouse reporting. We have also sought the advice from other institutions who report to the Clearinghouse. Our corrective action will involve several parts. • First, we will add more graduation only submissions to our Clearinghouse schedule to ensure they are getting reported in a timely manner. • Second, we will investigate where our Clearinghouse reports are pulling the graduation date form our Student Information System (Banner) to ensure those fields are accurate. • Third, we will review our process for determining degree conferral dates to ensure it aligns with our reporting schedule. • Fourth, over this past summer (2023) we worked with staff to clarify student withdrawal procedures. We will continue to do that. • Fifth, we will continue to take advantage of Clearinghouse training and other related training opportunities. • Sixth, we will be proactive in confirming that the Clearinghouse has received our submissions and has processed them in a timely manner. Name of the contact person responsible for corrective action: Cheryl Fisk, Registrar Planned completion date for corrective action plan: June 1, 2024
ALN No. 93.498, Provider Relief Fund; Award Year: Period 5: January 1, 2022 to June 30, 2022 Finding: Activities Allowed or Unallowed – The controls were not sufficient to ensure that depreciation expense for capital purchases were excluded when the capital expense was also submitted for program re...
ALN No. 93.498, Provider Relief Fund; Award Year: Period 5: January 1, 2022 to June 30, 2022 Finding: Activities Allowed or Unallowed – The controls were not sufficient to ensure that depreciation expense for capital purchases were excluded when the capital expense was also submitted for program reimbursement. Status: Corrective action in progress. Corrective Action: Internal controls will be strengthened in future periods to ensure that ledger details are appropriately filtered to exclude depreciation expense for costs already considered during the review of capital expenditures. The Director of Finance will review ledger details prior to submission to ensure only appropriate ledger accounts are included in requests for reimbursement. Person(s) Responsible for Implementing: Jia Paulucci, Director of Finance and Lindsey Soboloski, Controller Implementation Date: February 12, 2024
Recommendation: CLA recommends someone other than the preparer of Return of Title IV calculations review said calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: All Return of Title IV calculation...
Recommendation: CLA recommends someone other than the preparer of Return of Title IV calculations review said calculations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: All Return of Title IV calculations will be reviewed by another person in the Financial Aid Department, other than the preparer, for accuracy, completeness, and timeliness. Name(s) of the contact person(s) responsible for corrective action: David Fisher, dlfisher@neo.edu Planned completion date for corrective action plan: November 2023
Finding 370790 (2023-002)
Significant Deficiency 2023
The University has made all corrections to the identified records. The 21-22 audit, which ended in the Spring of 2023, identified similar issues regarding NSLDS enrollment reporting of some records. A corrective action plan was put in place at that time, however, a portion of the 22-23 year had alre...
The University has made all corrections to the identified records. The 21-22 audit, which ended in the Spring of 2023, identified similar issues regarding NSLDS enrollment reporting of some records. A corrective action plan was put in place at that time, however, a portion of the 22-23 year had already transpired, thus these additional findings in the current audit year. The errors were partly the result of reporting data challenges between the University's Anthology system, the National Student Loan Clearinghouse and NSLDS. The University also recently completed the institutional alignment of term and enrollment status definitions between the Financial Aid and the Center for Graduate and Professional Studies. Additional controls and staff training have also been implemented to identify errors and processes to correct records going forward, which will include adding NSLDS access for the Registrar. The University is continuing its review of practices and determination of any additional control needs.
Finding 370789 (2023-001)
Significant Deficiency 2023
The University agrees with the finding. The 21-22 audit, which ended in the spring of 2023, identified similar issues regarding Title IV credit balances. A corrective action plan was put in place at that time, however, a portion of the 22-23 year had already transpired, thus these additional finding...
The University agrees with the finding. The 21-22 audit, which ended in the spring of 2023, identified similar issues regarding Title IV credit balances. A corrective action plan was put in place at that time, however, a portion of the 22-23 year had already transpired, thus these additional findings in the current audit year. The occurrence of Title IV credit balances occurs primarily with graduate program students. A review was conducted of current internal control processes and an evaluation of additional reporting within the student information system was done to assist in identifying these Title IV credit balances in a more timely manner. Title IV credit balances were monitored during the Spring 2023 terms and new procedures have been put in place for the Fall 2024 term.
View Audit 292453 Questioned Costs: $1
The Foundation remedied the deficiency by depositing the required amount into the account and has an ongoing autopay set up to ensure the monthly amounts are deposited. In addition, the Foundation will reconcile the accounts regularly to ensure the requirement for the account is met.
The Foundation remedied the deficiency by depositing the required amount into the account and has an ongoing autopay set up to ensure the monthly amounts are deposited. In addition, the Foundation will reconcile the accounts regularly to ensure the requirement for the account is met.
Condition: The University did not return Title IV funds within the required time frame for certain students who required a post withdrawal disbursement. Planned Corrective Action: In response to identified delays in returning Title IV funds within the stipulated time frame for post withdrawal disbur...
Condition: The University did not return Title IV funds within the required time frame for certain students who required a post withdrawal disbursement. Planned Corrective Action: In response to identified delays in returning Title IV funds within the stipulated time frame for post withdrawal disbursements, an immediate corrective action plan has been initiated. This plan involves a thorough review of internal processes to identify and rectify procedural gaps contributing to the delays. Staff training sessions are being conducted to reinforce understanding and compliance with Title IV regulations, with a particular emphasis on the importance of timely disbursements. Contact person responsible for corrective action: N. Chad Curley Anticipated Completion Date: December 2022
Finding 370779 (2023-006)
Significant Deficiency 2023
After consultation with the National Clearinghouse (NCH), and written guidance from the U.S. Department of Education (ED), the Campus-Level enrollment effective date would not change because the enrollment level did not change. Clemson University will work with the NCH and utilize their audit suppor...
After consultation with the National Clearinghouse (NCH), and written guidance from the U.S. Department of Education (ED), the Campus-Level enrollment effective date would not change because the enrollment level did not change. Clemson University will work with the NCH and utilize their audit support to further explore this scenario and determine what would need to be changed with field mapping and review, if anything. Anticipated Completion Date: June 1, 2024 Person Responsible for Corrective action: Cecil (Rock) McCaskill, Associate Registrar Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu
Finding 370778 (2023-005)
Significant Deficiency 2023
The staff performing stale-dated check processing were notified of the audit finding and have received training. We have engaged with our banking partners to develop a report of outstanding checks to be available to Student Financial Services staff to identify aged outstanding student refund checks....
The staff performing stale-dated check processing were notified of the audit finding and have received training. We have engaged with our banking partners to develop a report of outstanding checks to be available to Student Financial Services staff to identify aged outstanding student refund checks. Student Financial Services staff will communicate with students who have outstanding checks as a proactive measure to decrease the volume of uncashed stale-dated checks. Anticipated Completion Date: October 31, 2023 Person Responsible for Corrective action: Rebecca Pruitt, Director of Student Financial Services Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu
Finding 370770 (2023-002)
Significant Deficiency 2023
The University’s Director of Financial Compliance will implement an additional step to email the University’s Controller for approval prior to drawdown of federal funds and will follow up with a screenshot of the actual drawdown for validation. Anticipated Completion Date: September 18, 2023 Person ...
The University’s Director of Financial Compliance will implement an additional step to email the University’s Controller for approval prior to drawdown of federal funds and will follow up with a screenshot of the actual drawdown for validation. Anticipated Completion Date: September 18, 2023 Person Responsible for Corrective action: Karen Robbins, Director of Financial Compliance Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu
Finding 370769 (2023-001)
Significant Deficiency 2023
The Payroll Department has taken immediate action to develop additional safeguards to ensure changes in pay records are accurately reflected on pay lines. We developed monitoring reports to review data extracted from Kronos to data loaded to pay lines. The central Payroll team will use these reports...
The Payroll Department has taken immediate action to develop additional safeguards to ensure changes in pay records are accurately reflected on pay lines. We developed monitoring reports to review data extracted from Kronos to data loaded to pay lines. The central Payroll team will use these reports to identify potential discrepancies and correct pay lines prior to giving department liaisons access to the system to review payroll data. Additionally, Payroll will conduct its routine Kronos Security Audit with Business Officers in October. Once complete, Payroll will communicate with designated HR/Payroll Liaisons and Kronos timekeepers to remind them of their roles and responsibilities as it pertains to monitoring and reviewing payroll data during payroll processing. Lastly, Payroll has worked with Human Resources IT to develop a query that will mimic the paysheets and provide an additional review tool at the department and budget center level. Once fully tested it will be rolled out to the Business Officers to assist in the payroll review process. Anticipated Completion Date: December 31, 2023 Person Responsible for Corrective action: Amelia Hood, Director of Payroll Contact/Responsible Party: Sherri Rowland, AVP and Controller Contact Information: sherrir@clemson.edu
To Whom it May Concern: The purpose of the Corrective Action Plan (CAP) is to define corrective actions for resolving any non-conformances identified during the single audit for Fiscal Year 2023. Federal Award Findings and Questioned Costs Finding 2023-001 - Material Weakness in Internal Control -...
To Whom it May Concern: The purpose of the Corrective Action Plan (CAP) is to define corrective actions for resolving any non-conformances identified during the single audit for Fiscal Year 2023. Federal Award Findings and Questioned Costs Finding 2023-001 - Material Weakness in Internal Control - Reporting Assistance Listing Number: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Not Applicable Award Number/Year: Not Applicable / 2023 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Recipients of Provider Relief Funds (PRF) payments must also comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition/Context: The Company did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. For the one report filed during the award year it was noted to include incorrect lost revenue totals, due to clerical errors and the exclusion of certain affiliates. In addition, the reports tested did not contain a documented review and approval of the reports prior to submission. Effect: The amounts reported to Health Resources and Services Administration (HRSA) were not in accordance with established U.S. Department of Health and Human Services reporting guidance. Total cumulative lost revenue should be $13,893,503. Questioned Costs: None reported. Cause: Lack of management oversight. Recommendation: We recommend that management review and update, as needed, their procedure for completion of the reporting to ensure that a review and approval of such reporting is completed and documented prior to submission. Additionally, we recommend that management revise their lost revenue totals in any future submissions. Views of Responsible Officials: Management will revise policies and update cumulative lost revenue for any future HRSA PRF Reporting Portal submissions and retain documented proof that the reports were reviewed prior to filing. In addition, revised lost revenues of $13,893,503 exceed cumulative PRF payments applied to lost revenues of $1,626,560. Date of anticipated Completion – March 15, 2024 Person/Persons responsible for completion – Jarrod Leo, CFO and Michele Brown, Senior Director of Fiscal Services Sincerely, Jarrod Leo Chief Financial Officer
FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Material Weakness Condition and Context There was no evidence that the Direct Certifications were correctly and properly included in the software system, or that there was an oversight, review, or approval pr...
FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Material Weakness Condition and Context There was no evidence that the Direct Certifications were correctly and properly included in the software system, or that there was an oversight, review, or approval process over the Direct Certifications. Contact Person Responsible for Corrective Action: Lori Boyce Contact Phone Number and Email Address: 765-653-3148 lboyce@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service Director will have the Guidance Secretary check and initial that the Food Service Director has completed the Direct Certification correctly. Anticipated Completion Date: 2/2024
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