Corrective Action Plans

Finding 10472 (2023-002)

Significant Deficiency 2023

OR

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Christopher Natelborg (Director of Financial Aid) and Dawn Sallee-Justesen (Director of Enrollment Services) will implement the following procedures and internal controls to ensure accurate dates are reported to NSLDS that agree with District records: • For NSLDS Enrollment Reporting purposes, 34 CF...

Christopher Natelborg (Director of Financial Aid) and Dawn Sallee-Justesen (Director of Enrollment Services) will implement the following procedures and internal controls to ensure accurate dates are reported to NSLDS that agree with District records: • For NSLDS Enrollment Reporting purposes, 34 CFR 685.305(c) requires schools to report the same withdrawal date that the school used for the return of Title IV funds (R2T4) purposes under 668.22(b) or (c). That is, the effective date for the withdrawn (‘W’) status is the withdrawal date used by the school in the R2T4 calculation. To ensure reporting is accurate, the Office of Financial Aid will communicate to the Registrar the specific student files and the dates of withdrawal used for any unofficial withdrawal R2T4 calculations after each term and the Registrar will update the student’s date of withdrawal on file with NSLDS within the required enrollment reporting deadlines. • The Director of Financial Aid and Director of Enrollment Services will also explore Information Technology automating the unofficial withdrawal date reporting to NSLDS. These corrective actions will be implemented by February 2024, including updating the dates in NSLDS for the 2023 summer and fall term unofficial withdrawals.

View Audit 14137

Finding 10437 (2023-004)

Material Weakness 2023

Solano Community College District

CA

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking § 200.303

2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures use...

2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures used by the awarding team (Financial Aid) and the disbursement team (Fiscal Services). The Financial Aid team was operating with a set of pre-pandemic instructions that had them contact students to fix their address information (the typical reason that disbursements timeout) and send a list of students with verified addresses to Fiscal Services for reissuing. Nothing in their procedures mentioned the need to rescind aid—only the need to verify addresses to allow funds to reach students. The Fiscal Services team’s procedures, on the other hand, assumed the Financial Aid team was rescinding aid as necessary and thus would reissue repeatedly as long as the funds remained awarded in the school’s information system, even in cases where the initial disbursement had been made more than 240 days prior. The combination of these two procedures led to the findings in this year’s audit and last year’s audit, as well. The Financial Aid team’s procedures were updated and presented to the team on October 4, 2023. These new procedures included:  Directions on how to rescind funds  A policy statement requiring recission when the time since first disbursement has exceeded 90 days (an institutional policy that is stricter than the 240 days allowable under federal regulations)  A clear set of instructions on how to make the determination to rescind funds. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: October 2023 for procedure correction. February 2024 for completed review of affected students in audit list.

View Audit 14106

Finding 10433 (2023-003)

Significant Deficiency 2023

Solano Community College District

CA

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

2023-003: NSLDS Enrollment Reporting Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District will review its enrollment reporting proc...

2023-003: NSLDS Enrollment Reporting Recommendation: We recommend that the District review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The District will review its enrollment reporting procedures to ensure information is accurately reported to NSLDS as required by regulations. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: Spring 2024

View Audit 14106

Finding 10429 (2023-002)

Significant Deficiency 2023

Solano Community College District

CA

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: This issue was discovered during the audit process and the staff member associated with this error was made aware of...

Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: This issue was discovered during the audit process and the staff member associated with this error was made aware of it in July 2023. Refresher training occurred during August 2023 and we have added members to the R2T4 calculation team in December 2023 in hopes of spreading workload and allowing more time to complete calculations and returns before the relevant deadlines. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: January 2024

View Audit 14106

Finding 10428 (2023-001)

Significant Deficiency 2023

Solano Community College District

CA

Questioned Costs Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather th...

2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather than the cumulative number that includes transfer units, when awarding a student in our small BS Biotechnology program. Student had completed 43.5 credits at Solano by the beginning of the aid year. As a result, the student was awarded a second-year subsidized amount when they were eligible for the third year and beyond amount. This resulted in the student receiving $1,000 less subsidized loans than they were eligible for. In July 2023, we trained the team to watch for this issue and evaluated the procedure log that we use for processing Direct Loans. This log now includes two checks that are relevant to ensuring subsidized loan amounts are correct: 1. Confirm the level of the student. If the student is in our BS Biotechnology program, they may have additional eligibility than the standard first-year and second-year loans that we normally process as a community college. 2. If the loan is a single-term loan, is the full subsidized eligibility exhausted before awarding any unsubsidized loan amounts? The student’s file was corrected on COD on 8/3/2023 to reflect a $5,500 subsidized award. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: August 2023

View Audit 14106 Questioned Costs: $1

Finding 10427 (2023-001)

None 2023

Invest Puerto Rico Inc.

PR

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Special Tests & Provisions

We will review and include an amendment to all FY2023 and FY2024 contracts as follows: - Contracts of amounts in excess of $150,000 must contain a provision that requires the non-Federal award to agree to comply with all applicable standards, orders or regulations issued pursuant to the Clean Air Ac...

We will review and include an amendment to all FY2023 and FY2024 contracts as follows: - Contracts of amounts in excess of $150,000 must contain a provision that requires the non-Federal award to agree to comply with all applicable standards, orders or regulations issued pursuant to the Clean Air Act (42 U.S.C. 7401–7671q) and the Federal Water Pollution Control Act as amended (33 U.S.C. 1251–1387). - Contractors that applied to bids in excess of $100,000 must contain a certification pursuant to the Byrd AntiLobbying Amendment (31 U.S.C. 1352). Each tier certifies to the tier above that it will not and has not used Federal appropriated funds to pay any person or organization for influencing or attempting to influence an officer or employee of any agency, a member of Congress, officer or employee of Congress, or an employee of a member of Congress in connection with obtaining any Federal contract, grant or any other award covered by 31 U.S.C. 1352.

View Audit 14096

Finding 10402 (2023-001)

Material Weakness 2023

First Baptist Church Capitol Hill Homes, Inc. D/b/a Kelly Miller Smith Towers

TN

Questioned Costs HUD Housing Programs Reporting

Auditee Response: The Board of Directors and management worked with the auditors to submit and certify to the FAC the Single Audit Reporting Packages for the years ended April 30, 2022 and 2021. This was completed on July 31, 2023. The Audit Committee of the Board of Directors will insure that fu...

Auditee Response: The Board of Directors and management worked with the auditors to submit and certify to the FAC the Single Audit Reporting Packages for the years ended April 30, 2022 and 2021. This was completed on July 31, 2023. The Audit Committee of the Board of Directors will insure that future Single Audit Reporting Packages for the year ending April 30, 2023 and beyond with be remitted in accordance with federal regulations. The Board of Directors and management will work with the prior auditors to insure that missing FAC submissions for the years ended April 30, 2020 and prior will be submitted and certified as applicable and in accordance with federal regulation.

View Audit 14064 Questioned Costs: $1

Finding 10400 (2023-001)

Significant Deficiency 2023

College of Dupage Community College District 502

IL

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education College of DuPage, Community College District Number 502 (the College), respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: CliftonLarsonAllen LLP, Oak Brook, Illinois Audi...

U.S. Department of Education College of DuPage, Community College District Number 502 (the College), respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: CliftonLarsonAllen LLP, Oak Brook, Illinois Audit period: July 1, 2022 – June 30, 2023 The findings from the schedule of findings, responses, and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Financial Statement Audit: None Findings – Federal Award Programs Audits: Department of Education 2023‐001 – Enrollment Status Reporting Recommendation: We recommend that the College review its procedures to ensure enrollment status changes are reported to NSLDS accurately, as required by regulations. Planned Corrective Action: The College of DuPage has reviewed and agrees with the enrollment reporting finding. The College has already taken multiple steps to resolve all issues ensuring complete, accurate and timely reporting. However, all those steps have not fully resolved the issue with enrollment reporting. As such, we will be working on a long‐term system improvement with the goal of limiting issues and future audit findings. The Financial Aid Office and the Registrar’s Office will work closely with the Information Technology department to automate a process of capturing unofficial withdrawal information, using the NSLDS template and then uploading that report directly to NSLDS on a weekly basis. The College will continue to send records to the National Student Clearinghouse and use this new report to supplement reporting and resolve the issues with reporting unofficial withdrawals. The goal is to implement this new report by June 30, 2024. Contacts Responsible for Corrective Action: Dr. Diana Del Rosario, Assistant Provost, Student Affairs Jill Pierson, Registrar Scott Brady, CFO & Treasurer Anticipated Completion Date: June 30, 2024 If the U.S. Department of Education has questions regarding this plan, please do not hesitate to call me at (630) 942‐2219.

View Audit 14059

Finding 10380 (2023-001)

Material Weakness 2023

Massac County Community Unit School District No. 1

IL

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Name of Contact Person: Jason Hayes, Superintendent. Recommendation: We recommend the District check the Excluded Parties List System or collect certifications from the entity for any vendor in which the District expects to spend more than $25,000 of federal grant funds for the year. Corrective ...

Name of Contact Person: Jason Hayes, Superintendent. Recommendation: We recommend the District check the Excluded Parties List System or collect certifications from the entity for any vendor in which the District expects to spend more than $25,000 of federal grant funds for the year. Corrective Action: The District will ensure they comply going forward.

View Audit 14045

Finding 10356 (2023-007)

Significant Deficiency 2023

Clatsop Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the college implement procedures to ensure direct loan reconciliations are performed monthly and reviewed by someone other than the preparer. Explanation of disagreement with audit finding: There is no...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the college implement procedures to ensure direct loan reconciliations are performed monthly and reviewed by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is aware of the requirement to perform direct loan reconciliation. We are now appropriately staffed with monthly reconciliation being performed by the Assistant Director and being sent to the Director of Accounting for review. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse & Layla Solar Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10352 (2023-006)

Significant Deficiency 2023

Clatsop Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: Th...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College implement procedures to ensure all requirements of a Tier One arrangement for Third Party Servicers are being met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The links to the BankMobile contract and costs have been posted on the College web page that explains student stipends and the College use of Bank Mobile to provide these stipends. The links have been given to the College Financial Aid Director to upload to the US Dept of Education. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10348 (2023-005)

Material Weakness 2023

Clatsop Community College

OR

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit ...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend the College draft and implement IT policies and create an updated WISP to ensure the College is compliant with the GLBG Safeguards Rule. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clatsop Community College is working on its information security plan, as well as vendor and change management plans. The plans will be presented to College Council in spring 2024 before they are finalized. Name(s) of the contact person(s) responsible for corrective action: Greg Riehl Planned completion date for corrective action plan: June 30, 2024

View Audit 14009

Finding 10344 (2023-004)

Material Weakness 2023

Clatsop Community College

OR

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There i...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.007, 84.033 Recommendation: We recommend a process be put in place to ensure documentation is maintained and available, particularly when making software changes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college will create a stronger infrastructure around records and reporting by reducing the number of staff who have access to student coding. The number of staff allowed access to student program changes and enrollment transactions results in a significant number of errors on the NSC report due to effective dating issues. The volume of errors is not manageable with the current staff and will continue to be so regardless of additional infrastructure if changes in the business process are not implemented. The Registrar is creating a system for effective dating and reducing the number of employees with access to student program coding and enrollment transactions as part of the implementation of the new ERP system Colleague. In addition, the Registrar will create a student coding and effective dating chart that outlines the dates and deadlines associated with allowable student program changes and enrollment transactions. The reduction in staff access and implementation of effective dating in alignment with the new enterprise system Colleague and NSC reporting requirements will result in compliance with NSLDS reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Siv Barnum Planned completion date for corrective action plan: FY2024-25

View Audit 14009

Finding 10343 (2023-003)

Significant Deficiency 2023

Clatsop Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid Eligibility § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Explanation of disagreement with audit finding: There is no disag...

Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend that the College review their awarding procedures and implement procedures to ensure direct loans are paid within the aggregate limits. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office is now appropriately staffed and extra time will be taken to ensure NSLDS is being reviewed prior to loan origination. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleysne & Layla Solar Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10342 (2023-002)

Significant Deficiency 2023

Clatsop Community College

OR

Matching / Level of Effort / Earmarking Student Financial Aid Reporting § 200.303

Student Financial Aid Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: The...

Student Financial Aid Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The financial aid office and student accounts office will work together to clearly communicate the timing of aid being applied to student accounts and being reported to COD to ensure both actions are happening on the same day. Name(s) of the contact person(s) responsible for corrective action: Sarah Geleynse Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10340 (2023-001)

Significant Deficiency 2023

Clatsop Community College

OR

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

Education Stabilization Fund (ESF) – Assistance Listing No. 84.425E and 84.425F Recommendation: We recommend the college review their reporting procedures to ensure they encompass controls regarding timeliness of reporting. Explanation of disagreement with audit finding: There is no disagreement wi...

Education Stabilization Fund (ESF) – Assistance Listing No. 84.425E and 84.425F Recommendation: We recommend the college review their reporting procedures to ensure they encompass controls regarding timeliness of reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All ESF funds were expended as of June 30, 2023, so there is no continuing reporting requirement. Name(s) of the contact person(s) responsible for corrective action: Margaret Antilla Planned completion date for corrective action plan: Completed

View Audit 14009

Finding 10322 (2023-001)

Significant Deficiency 2023

Illinois Central College District 514

IL

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in pl...

The College meets or exceeds the system and data security requirements as stipulated in the GLBA and best industry practice and standards for IT system security. There are no identified weaknesses or concerns for the security of College data. Formal documentation of procedures and process are in place and being formalized by the Institution and the College will be in compliance with the requirement for formal written standards going forward.

View Audit 13983

Finding 10297 (2023-002)

Significant Deficiency 2023

University of South Carolina

SC

Matching / Level of Effort / Earmarking Reporting Significant Deficiency

HEERF ANNUAL REPORTING Recommendation: We recommend that the University monitor the reporting requirements of all grants, to ensure they stay in compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The...

HEERF ANNUAL REPORTING Recommendation: We recommend that the University monitor the reporting requirements of all grants, to ensure they stay in compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University will monitor reporting requirements for HEERF funds for its annual report and will amend the prior report as needed for compliance. Name(s) of the contact person(s) responsible for corrective action: Mandy Kibler, Associate Vice President and University Controller Planned completion date for corrective action plan: The University will submit the final HEERF Annual Report for CY2023 in spring 2024 and will amend the CY2022 in spring 2024 to ensure reporting requirements are met.

View Audit 13962

Finding 10287 (2023-002)

Significant Deficiency 2023

Laramie County Community College

WY

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Corrective Action: The College’s Return of Title IV Funds procedure was reviewed. The following language was revised in the post-withdrawal disbursement (PWD) section of this procedure as a control to ensure that advanced written notification is not missed in the future: A written notification will...

Corrective Action: The College’s Return of Title IV Funds procedure was reviewed. The following language was revised in the post-withdrawal disbursement (PWD) section of this procedure as a control to ensure that advanced written notification is not missed in the future: A written notification will be sent to a student (or parent) that is eligible for a PWD of Federal Direct Loan within 30 days of the date of determination. The type and amount of Title IV loan funds that will be credited to the student’s charges and the amount that will directly disburse will be offered to the student, or the parent in the case of a PLUS Loan. The notification will explain that the student or parent can accept all or part of the loan disbursement and will advise the student or parent that no post-withdrawal disbursement of Title IV loan funds will be made unless the school receives a confirmation response within the established timeframe of 14 days. Please note that loan PWDs are very rare at the College because the vast majority of our students that wish to borrow complete their loan requirements and receive their loan disbursement prior to their withdrawal date. In the case of the student noted in the finding, the student completed his loan requirements (i.e., master promissory note and loan entrance counseling) only a couple of days before the date he became ineligible. We acknowledge an advanced written notice was not sent, but please note that a written notification was sent to the student immediately following the loan disbursement informing the student about his right to cancel all or part of the loan and the procedures and timeframe in which to do so. Anticipated Completion Date: July 1, 2023 Contact Person: Brandi Payne Cervera

View Audit 13927

Finding 10269 (2023-001)

Significant Deficiency 2023

Western Wyoming Community College

WY

Questioned Costs Student Financial Aid Eligibility

Pell This finding is the result of manual awarding and revisions by staff that are no longer employed by WWCC. To prevent Pell underpayment, Colleague was reconfigured for 2023-2024 to accurately award and revise awards when students add courses prior to the census date. Additionally, a regular revi...

Pell This finding is the result of manual awarding and revisions by staff that are no longer employed by WWCC. To prevent Pell underpayment, Colleague was reconfigured for 2023-2024 to accurately award and revise awards when students add courses prior to the census date. Additionally, a regular review of the Pell Eligibility Variance Report in Colleague (which displays students with a Colleague calculated Pell that differs from what the student has been awarded) will identify any student not awarded to their full Pell eligibility. Loan This finding is the result of a miscalculation of single term costs of attendances (COA) for students enrolling spring only. To address the 2022-2023 overpayments identified, all students enrolled for the spring single term while receiving Title IV funding had their COA recalculated, financial need determined using the four (4) month EFC, and SEOG, and subsidized/unsubsidized loan eligibility recalculated. Where required, the SEOG, and subsidized/unsubsidized loans were adjusted to actual eligibility and the student account and COD updated. Documentation that this action was completed has been provided to the auditor. For 2023-2024, Colleague was reconfigured to calculate COA components at a per term level, instead of at an annual level (which was used in 2022-2023). Colleague was also reconfigured to calculate the EFC for a single term student so that the financial need could be determined correctly. As a result, single term students will receive a single term COA and EFC to accurately the student’s financial need. SEOG and subsidized/unsubsidized loans will be awarded based on financial need and remaining costs. Anticipated Completion Date: December 31, 2023 Contact Person: Amy Murphy, Dean of Outreach and Workforce Development & Interim Dean of Enrollment Management

View Audit 13919 Questioned Costs: $1

Finding 10259 (2023-010)

Significant Deficiency 2023

Heritage University

WA

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

2023-010 – Special Tests and Provisions – Federal Perkins Loan Liquidation – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University reconcile the information to the most recent filed FISAP to ensure the entire portfolio of Perkins loans wa...

2023-010 – Special Tests and Provisions – Federal Perkins Loan Liquidation – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University reconcile the information to the most recent filed FISAP to ensure the entire portfolio of Perkins loans was properly liquidated. Planned corrective actions: To ensure the Perkins loan portfolio was correctly liquidated, the University will reconcile the data with the most current FISAP filed. Name of Responsible Party: 1. Financial Aid Director 2. Alysia Stevens, Controller 3. VP of Administration/CFO 4. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

View Audit 13897

Finding 10253 (2023-009)

Significant Deficiency 2023

Heritage University

WA

Questioned Costs Student Financial Aid Special Tests & Provisions

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to su...

2023-009 – Special Tests and Provisions – Return of Title IV Funds (R2T4) – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University review their policies and procedures to ensure that all withdrawals have the appropriate documentation to support the withdrawal date used in the calculation. Planned corrective actions: In order to make sure that all withdrawals have the proper evidence to support the withdrawal date used in the computation, the University will evaluate its rules and procedures. Name of Responsible Party: 1. Mary Neal, Registrar 2. Financial Aid Director 3. Melissa Hill, Provost 4. VP of Administration/CFO 5. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

View Audit 13897 Questioned Costs: $1

Finding 10248 (2023-007)

Significant Deficiency 2023

Heritage University

WA

Student Financial Aid Reporting Subrecipient Monitoring

2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accu...

2023-007 – Special Tests and Provisions - Enrollment Reporting – Significant Deficiency in Internal Controls over Compliance Recommendation: The auditors recommend the University follow and enhance existing policies to ensure all student changes in status are identified timely and submitted accurately within the required time frame. The auditors also recommend the University establish a formal internal monitoring control whereby a designated individual with NSLDS access, on a sample basis, spot checks the status updates on NSLDS so to internally audit the National Student Clearinghouse submissions. Planned corrective actions: The University will adhere to current regulations and improve them if necessary to guarantee that all student status changes are recognized promptly and filed correctly within the allotted period. In order to internally audit the National Student Clearinghouse submissions, the University established a formal internal monitoring system wherein a designated individual with NSLDS access, on a sample basis, spot-checks the status updates on NSLDS. Name of Responsible Party: 1. Mary Neal, Registrar 2. Financial Aid Director 3. Melissa Hill, Provost 4. VP of Administration/CFO 5. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

View Audit 13897

Finding 10245 (2023-006)

Material Weakness 2023

Heritage University

WA

Reporting Material Weakness Matching / Level of Effort / Earmarking § 200.329

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University create an internal control to obtain reporting requirements for each award received by the University. The auditors recommend a standard ...

2023-006 – Reporting – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University create an internal control to obtain reporting requirements for each award received by the University. The auditors recommend a standard process be implemented for each award to track the due dates to ensure they are completed timely. Planned corrective actions: The university will create an internal control policy to ensure that it has the necessary paperwork for each award it receives. This will be the routine procedure followed for every award in order to keep track of the deadlines and finish on time. Name of Responsible Party: 1. Grant P.I’s 2. Terri Slack, Fiscal Officer 3. Yolanda Maltos, Grant Accountant 4. Melissa Hill, Provost 5. Alysia Stevens, Controller 6. VP of Administration, CFO 7. Dr. Andrew Sund, President Anticipated completion date: 6/30/2024

View Audit 13897

Finding 10217 (2023-001)

Significant Deficiency 2023

Laramie County School District #1

WY

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.208 § 200.318 § 200.339

2023-001: Special Education Cluster – Procurement Context/Condition - Of the four procurement transactions subjected to testing, there were two professional service contracts that the District did not have documentation supporting the sole source procurement method. Corrective Action Plan – Laramie ...

2023-001: Special Education Cluster – Procurement Context/Condition - Of the four procurement transactions subjected to testing, there were two professional service contracts that the District did not have documentation supporting the sole source procurement method. Corrective Action Plan – Laramie County School District No. 1 (LCSD1) appreciates the thorough review conducted by the auditing team, identifying the lack of documentation for two sole source contracts for special education trainers hired in response to the Wyoming Department of Education’s monitoring review. In response, LCSD1 has undertaken a comprehensive corrective action plan to rectify the identified issues and prevent future occurrences. Immediate steps include a detailed review of the existing contract, identification of missing documentation, engagement with legal counsel to ensure compliance, and the development of clear procedures for documenting sole source justifications. To address potential gaps in staff understanding, LCSD1 has implemented additional training programs and reviews by procurement staff. LCSD1 will also evaluate federal, state and district procurement policies and initiate additional internal monitoring requirements for special education contracts. LCSD1 does not dispute the finding and will continue to improve processes and procedures with a focus on periodic reviews to enhance procurement practices. Contact Person – Jed Cicarelli, Chief Financial Officer Anticipated Completion Date – Immediately

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