Corrective Action Plans

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Finding 2023‐003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the b...
Finding 2023‐003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the balance in comparison to the required minimum reserve balance. Responsible Individuals: Mandy Robinson, Administrator Corrective Action Plan: Management will ensure reviews separate from the preparer of the reconciliation for the program's reserve fund and the reserve fund balance in comparison to the required minimum reserve balance is completed with formal documentation noting the reviews. Anticipated Completion Date: 03/31/2024
Management has reviewed the finding and is in agreement with the reported deficiency as a result of staffing levels. Corrective action will include evaluation of existing accounting staffing levels, review of current accounting policies related to separation of duties, and the addition of a requirem...
Management has reviewed the finding and is in agreement with the reported deficiency as a result of staffing levels. Corrective action will include evaluation of existing accounting staffing levels, review of current accounting policies related to separation of duties, and the addition of a requirement for secondary approval related to journal entries, SEFA preparation, and draw requests for/from federal grant programs. To be completed within fiscal year 2024.
Finding 4290 (2023-001)
Significant Deficiency 2023
Recommendation: We recommend the College evaluate and enhance the college’s financial aid awarding procedures to prevent future instances of over-awarding. We recommend the College establish a system for ongoing monitoring of financial aid awards to identify and address discrepancies in a timely man...
Recommendation: We recommend the College evaluate and enhance the college’s financial aid awarding procedures to prevent future instances of over-awarding. We recommend the College establish a system for ongoing monitoring of financial aid awards to identify and address discrepancies in a timely manner. Regularly review and update policies and procedures to adapt to changes in regulations and best policies. Corrective Action: The college financial aid office will review and update policies and procedures in the Clarendon College Financial Aid Handbook to establish system for ongoing monitoring of financial aid awards in order to identity and address discrepancies and potential over-awards in a timely manner. The system will include monitoring Cost Of Attendance, enrollment status, and unmet need. The policy/procedure will be reviewed and submitted for adoption by the CC Board of Regents for the Clarendon College Financial Aid Handbook by February 2024.
Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that ...
Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that there is an additional review of time and effort reports as part of the grant accounting, review and finalization process.
View Audit 6595 Questioned Costs: $1
Finding 2023-008 – Student Financial Assistance Cluster – Fraudulent Enrollment Condition City Colleges did not timely report information regarding potential fraudulent student enrollments to the Department of Education’s Office of Inspector General (OIG). City Colleges identified a total of 23 stu...
Finding 2023-008 – Student Financial Assistance Cluster – Fraudulent Enrollment Condition City Colleges did not timely report information regarding potential fraudulent student enrollments to the Department of Education’s Office of Inspector General (OIG). City Colleges identified a total of 23 students where the Enrollment and Admissions Departments discovered submission of fraudulent documents to verify residency. City Colleges performed a thorough investigation of student enrollment and verified that no aid was disbursed for these identified fraudulent enrollments Cause City Colleges experienced turnover in the Admissions Department and was training a new employee. The new employee did not have enough training or experience to identify fraudulent documents when the students enrolled with the college and registered for classes. City Colleges was not aware that this issue was required to be reported to the Department of Education. Corrective Action Taken or Planned: The College will review and monitor the Department of Education regulations. The Student Financial Aid will continue to train employees on the regulations and will timely report issues to the Department of Education. Contact Person: Tiffany Morrison, Associate Vice Chancellor – Financial Aid & Scholarship Anticipated Completion Date: In progress
Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic i...
Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic inventory of data, nothing where it’s collected, stored or transmitted. Cause City Colleges does not have a periodic data inventory in place. The policy is under development with an expected completion date of December 2023. Corrective Action Taken or Planned CCC will refresh the current data inventory and instate periodic inventory refresh procedures by December 31, 2023. Contact Person: Zarko Njakara, Interim CIO Anticipated Completion Date: December 31, 2023
Finding 2023-005– Student Financial Assistance Cluster Internal Control over Compliance Condition City Colleges did not have sufficient documentation that internal controls were in place and operating effectively relative to the following areas: • Allowable Activities: For each of the seven campus...
Finding 2023-005– Student Financial Assistance Cluster Internal Control over Compliance Condition City Colleges did not have sufficient documentation that internal controls were in place and operating effectively relative to the following areas: • Allowable Activities: For each of the seven campuses, City Colleges did not have sufficient supporting evidence that review controls were performed over the transfer, carryforward, carryback, and administrative cost calculations in the Fiscal Operations Report and Application to Participate (FISAP) for award year July 1, 2021 through June 30, 2022 submitted during fiscal year 2023. • Reporting: For each of the seven campuses, City Colleges did not have sufficient supporting evidence that secondary review controls were performed over FISAP data for award year July 1, 2021 through June 30, 2022 submitted during fiscal year 2023. Cause City Colleges did not formally document the additional reviews and approvals over the department’s review of the FISAP. Corrective Action Taken or Planned Financial Aid will develop and document a review/approval process that will detail accurate reporting, secondary reviews, and review/approval of FISAP submissions and completions. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
Finding 2023-004 – Cash Management – Excess Cash Condition During our cash management testing, we identified the following instances of excess cash: • Kennedy King College had excess cash for the Pell Grant Program ranging from $34,408 to $175,609 during the period of November 14, 2022 through Jan...
Finding 2023-004 – Cash Management – Excess Cash Condition During our cash management testing, we identified the following instances of excess cash: • Kennedy King College had excess cash for the Pell Grant Program ranging from $34,408 to $175,609 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Kennedy King College had excess cash for the Direct Loan Program ranging from $1,349 to $4,318 during the period of November 29, 2022 through December 13, 2022, from $1,508 to $3,948 during the period of January 6, 2023 through January 16, 2023 and from $3,207 to $5,137 during the period of June 15, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns, however, amounts were not returned within a seven-day period. • Truman College had excess cash for the Pell Grant Program ranging from $164,625 to $262,034 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Truman College had excess cash for the Direct Loan Program ranging from $2,731 to$8,669 during the period of January 20, 2023 through February 16, 2023 and from $752 to $10,028 during the period of April 28, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns; however, amounts were not returned within a seven-day period. Cause The College drew down funds available in the G5 system as opposed to drawing down expected student disbursement amounts. Corrective Action Taken or Planned District Office Financial Aid will develop and implement better controls and procedures for monitoring the timing of the draw downs and student disbursements as well as controls to monitor the return of excess cash, if any, within the 7-day period. During the middle of a semester, timely reconciliations will be prepared, reviewed and approved prior to the next draw down to ensure the acceptable amount is drawn down and disbursed timely to the students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
View Audit 6574 Questioned Costs: $1
Finding 2023-003 – Common Origination and Disbursement (COD) Reporting Condition For ten out of forty students tested (25%), the College did not report certain disbursements of financial aid to COD within the require fifteen days from the date of disbursement. In all instances, the disbursements we...
Finding 2023-003 – Common Origination and Disbursement (COD) Reporting Condition For ten out of forty students tested (25%), the College did not report certain disbursements of financial aid to COD within the require fifteen days from the date of disbursement. In all instances, the disbursements were reported one day late. Cause The financial aid office inadvertently miscalculated the reporting date. Corrective Action Taken or Planned Financial Aid will add additional monitoring controls of COD files to ensure timely reporting. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
Finding 2023-002 – Short-Term Program Completion and Placement Rates Condition The College did not achieve the required 70% completion rate for a short-term program. The College cannot demonstrate compliance with the gainful employment placement rate calculation for a short-term program. Cause The...
Finding 2023-002 – Short-Term Program Completion and Placement Rates Condition The College did not achieve the required 70% completion rate for a short-term program. The College cannot demonstrate compliance with the gainful employment placement rate calculation for a short-term program. Cause The financial aid office did not follow-up on the gainful employment of students. Corrective Action Taken or Planned The Financial Aid Office will work with campus leadership and staff to ensure an accurate reporting process is in place to track gainful employment and completion. Documentation will be required by campus leadership to show communication efforts for students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023
Finding 2023-001 – Enrollment Reporting Condition For four out of sixty students tested (7%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Cause Th...
Finding 2023-001 – Enrollment Reporting Condition For four out of sixty students tested (7%) who withdrew from City Colleges, the students’ withdrawal date reported to the National Student Loan Data System (NSLDS) for campus level and program level did not match the institution’s records. Cause The financial aid office does not have an effective system in place to ensure all official student status changes are reported to the lender accurately. Corrective Action Taken or Planned City Colleges sends enrollment files of all students to the National Student Clearinghouse monthly, who then reports CCC enrollment data to NSLDS. City Colleges (Records, Financial Aid, Decision Support and the Office of Information Technology) continues to meet bi-weekly to review and update the enrollment reporting logic to ensure the dates for student enrollment actions align at the campus level and the program level. Contact Person: Laura Clark, Associate Vice Chancellor, Academic Systems and Tiffany Morrison, Associate Vice Chancellor, Financial Aid. Anticipated Completion Date: May 1, 2024
U.S. Agency for International Development 2023-001 Collaboration for African Biodiversity (ABCG III) – Assistance Listing no. 98.001 Recommendation: Management should ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible...
U.S. Agency for International Development 2023-001 Collaboration for African Biodiversity (ABCG III) – Assistance Listing no. 98.001 Recommendation: Management should ensure retention of evidence to include dates of when suspension and debarment verifications are performed. Views of responsible officials: AWF management agrees with the finding and recommendation set forth and has developed a corrective action plan. The procurement and contracts manager is now ensuring that AWF captures the date when taking a screenshot from the OFCCP Debarred Companies list when conducting background checks on vendors so as to document that the search has been performed prior to entering into a contract with the vendor.
Federal Direct Loan exit interview information was sent to the student in question on October 27, 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they drop below a half-time enrollment status at the School. Anticip...
Federal Direct Loan exit interview information was sent to the student in question on October 27, 2023. Procedures will be improved to ensure Federal Direct Loan exit interviews are completed or information is sent to students when they drop below a half-time enrollment status at the School. Anticipated Completion Date: The corrective action was completed on October 27, 2023 Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659
Finding Reference 2023-001 Corrective Action Plan: • After the quarter end, the Compliance Manager will request a report containing Teacher Loan Forgiveness applications reviewed by Trellis during the quarter. • The Compliance Manager will select a random sample of five applications to review for ac...
Finding Reference 2023-001 Corrective Action Plan: • After the quarter end, the Compliance Manager will request a report containing Teacher Loan Forgiveness applications reviewed by Trellis during the quarter. • The Compliance Manager will select a random sample of five applications to review for accuracy and completeness. • The Compliance Manager will review all documentation submitted and ensure that Trellis systems are updated/documented accordingly. • The results of the review, including any exceptions noted, will be summarized, documented, and reported to the Manager of Customer Support, the Director of Operations, and the VP of Operations. Contact Person: Susan High Anticipated Completion Date: October 6, 2023
(1) Any contracts over $2,000 will include the proper language that the contractor must comply with the Davis-Bacon Act. These contracts will be reviewed by Business Administrator and Superintendent before being signed and (2) Weekly certified reports will be obtained from contractor and reminders h...
(1) Any contracts over $2,000 will include the proper language that the contractor must comply with the Davis-Bacon Act. These contracts will be reviewed by Business Administrator and Superintendent before being signed and (2) Weekly certified reports will be obtained from contractor and reminders have been set up with both parties to ensure this happens timely. Person Responsible: Cary Reese, Business Administrator Timeline: Management of the District will ensure all construction contracts using federal dollars will have the Davis-Bacon language in the contract-October 2023. Certified weekly payroll reports obtained from contractor-October 2023.
Recommendation: Implement policies and procedures that ensure required reports are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will updat...
Recommendation: Implement policies and procedures that ensure required reports are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures that ensure required reports are reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures that ensure the indirect cost calculation is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organizatio...
Recommendation: Implement policies and procedures that ensure the indirect cost calculation is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures that ensure the indirect cost calculation is reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures that ensure the cash management requirement is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organizat...
Recommendation: Implement policies and procedures that ensure the cash management requirement is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures that ensure the cash management requirement is reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in ...
Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures that ensure the calculation of the matching requirement is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to findin...
Recommendation: Implement policies and procedures that ensure the calculation of the matching requirement is reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures that ensure the calculation of the matching requirement is reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in ...
Recommendation: Implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Explanation of disagreement with audit finding: Management agrees with the audit finding. Action planned/taken in response to finding: Organization will update and implement policies and procedures surrounding the cash disbursement process that ensures all disbursements are reviewed and approved by a second, independent individual. Name(s) of the contact person(s) responsible for corrective action: Debbie Esparza Planned completion date for corrective action plan: January 31, 2024
The College agrees that Enrollment Reporting should be submitted in a timely manner. The College is actively working with the new SIS to ensure the ability to be able to produce the reports.
The College agrees that Enrollment Reporting should be submitted in a timely manner. The College is actively working with the new SIS to ensure the ability to be able to produce the reports.
2023-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2023 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct L...
2023-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2023 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $1,750 in Subsidized Loans and $1,000 in Unsubsidized Loans; however, the College awarded the student $1,750 in Subsidized loans and $1,250 in Unsubsidized loans which resulted in an over award of $250 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan During the audit for the year ending Jun 30, 2023, the financial aid office reviewed the finding and was able to refund the over-award of $250 in Unsub within the student’s loan period. Since the finding our Financial Aid Coordinator completed additional trainings related to the administration of Financial Aid. Within these trainings, successful completion of loan processing training was required. As of May 12, 2023, our Financial Aid Coordinator is a certified Financial Aid Administrator through the National Association of Financial Aid Administrators. Responsible Person for Corrective Action Plan Gregory Putra, Director of Financial Aid & Veterans Affairs Implementation Date of Corrective Action Plan 7/1/2023
View Audit 6494 Questioned Costs: $1
Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: An automated batch email process has been updated to ensure that all loan disbursement notifications will be sent the same day as the loans are disbursed. In addition to the automation, calendar reminde...
Name of Responsible Individual: Brian K. Blackburn, Director of Financial Aid Corrective Action: An automated batch email process has been updated to ensure that all loan disbursement notifications will be sent the same day as the loans are disbursed. In addition to the automation, calendar reminders have been set for all scheduled disbursement days. It will be the duty of the Director to ensure the process is successful and would only fall to the Assistant Director in times that the Director is unavailable. Anticipated Completion Date: November 9, 2023
Name of Responsible Individual: Terri Grice, University Registrar Corrective Action: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be rev...
Name of Responsible Individual: Terri Grice, University Registrar Corrective Action: The Registrar’s Office is continuously cross-training all team members so duties are cross-checked, shared by at least two team members, and completed in a timely manner. The reports used by this office will be reviewed on a frequent basis to ensure information is being reported as it was intended. The team will also meet with other departments on a frequent basis to ensure information is shared in a timely manner and continue to train on the regulations and policies between our institution, Clearinghouse, and NSLDS to ensure accurate reporting of information. Anticipated Completion Date: February 23, 2024
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