Corrective Action Plans

Finding 372676 (2023-005)

Significant Deficiency 2023

MA

Student Financial Aid Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

Management concurs with the recommendation. Berklee will review and enhance processes related to reporting key items to the COD System. The institution will also update key fields to accommodate changes during the awarding process to ensure they agree with records.

View Audit 293797

Finding 372675 (2023-004)

Significant Deficiency 2023

Berklee College of Music, Inc.

MA

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

Management concurs with the recommendation. Going forward, there will be at least two reviews of the FISAP prior to the annual filing, including all updates, to better ensure complete and accurate completion prior to filing with the U.S. Department of Education.

View Audit 293797

Finding 372674 (2023-003)

Significant Deficiency 2023

Berklee College of Music, Inc.

MA

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

Management concurs with the recommendations provided. Berklee will enhance its protocols to ensure adequate support is in place to document that reports are prepared and reviewed by appropriate individuals, that duties are appropriately segregated between preparer and review, and that reports are ac...

Management concurs with the recommendations provided. Berklee will enhance its protocols to ensure adequate support is in place to document that reports are prepared and reviewed by appropriate individuals, that duties are appropriately segregated between preparer and review, and that reports are accurately prepared and reviewed prior to posting with the U.S. Department of Education.

View Audit 293797

Finding 372648 (2023-003)

Material Weakness 2023

Martinsville Msd

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Finding 2023‐003 Finding Subject: COVID‐19 ‐ Education Stabilization Fund: Special Tests & Provisions ‐ Wage Rate Requirements Summary of Finding: The School Corporation did not have adequate policies or procedures to ensure that contracts in excess of $2,000 paid from federal grant funds included a...

Finding 2023‐003 Finding Subject: COVID‐19 ‐ Education Stabilization Fund: Special Tests & Provisions ‐ Wage Rate Requirements Summary of Finding: The School Corporation did not have adequate policies or procedures to ensure that contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. There was at least one vendor during the audit period that was subject to wage rate requirements; however, the School Corporation did not enter into an agreement with the vendor and obtain a contract that included a prevailing wage rate clause. The School Corporation also did not obtain weekly certified payrolls from the vendor completing the construction. Contact Person Responsible for Corrective Action: Kyle Stout, Director of Operations & Tiffany Grant, Grant Coordinator Contact Phone Number and Email Address: 765‐342‐6641 Kyle.Stout@msdmartinsville.org & Tiffany.Grant@msdmartinsville.org Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Operations will put out the requests for bids/proposals/contracts. The bids/proposals/contracts will be reviewed by the Director of Operations and the Grant Coordinator to ensure they are following our School Board policy #6325, Procurement – Federal Grants/Funds. If a contract is to be entered into with a vendor, that contract is sent to the School Board for approval. Once approved, the Grant Coordinator will retain the weekly payrolls from the contracted vendor to ensure that the Davis Bacon Prevailing Wage Requirements are being met. If the requirements of Davis Bacon are not being met, the Grant Coordinator informs the Director of Operations of non‐compliance. Anticipated Completion Date: February 2024

View Audit 293718

Finding 372643 (2023-002)

Material Weakness 2023

Martinsville Msd

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

Finding 2023‐002 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Summary of Finding: The School Corporation was required to submit an annual data report to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not l...

Finding 2023‐002 Finding Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Summary of Finding: The School Corporation was required to submit an annual data report 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. The School Corporation submitted two reports during the audit period; however, a single employee prepared and submitted the reports without evidence of a review or oversight process in place to prevent or detect and correct errors for the first report submission. Additionally, for the ESSER I Year 2 reporting, the ‘Total Mandatory Subgrant Amount Expended in Current Reporting Period’ was not supported by the School Corporation's records. Actual expenditures from a provided report did not agree to the amount submitted for the Annual Performance Reporting. The key line item ‘Total Mandatory Subgrant Amount Expended in Current Reporting Period’ for the ESSER I Year 2 report was determined to be overstated by $80,342. Contact Person Responsible for Corrective Action: Whitney Kuszmaul, District Treasurer & Tiffany Grant, Grant Coordinator Contact Phone Number and Email Address: (765) 342‐6641 Whitney.Kuszmaul@msdmartinsville.org & Tiffany.Grant@msdmartinsville.org Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Grant Coordinator works to collect the data from a couple different sources. The staff report information comes from our Payroll/HR department, the CE information comes from our Reporting Specialist and the financial data comes from District Treasurer. The Grant Coordinator requests a detailed report for the appropriate period and break down the detailed report by project/report categories. All of this information is then recorded in the DOE data sheet and is reviewed and tied back to the detailed reports provided by the District Treasurer. After review, the Grant Coordinator and the District Treasurer initial/sign off on the DOE data sheets. The Jot Form confirmation is retained with the DOE data sheets and supporting reports/documentation. Anticipated Completion Date: February 2024

View Audit 293718

Finding 372626 (2023-002)

Significant Deficiency 2023

Holy Family University

PA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames, as well as create accurate repor...

ALN: 84.268 Federal Direct Loan Program; 84.063 Federal Pell Grant Program Recommendation: It is recommended that policies and procedures are put in place to verify that the correct effective dates and status changes are reported to NSLDS within required time frames, as well as create accurate reports internally to track all students' whose status changed and verify against the roster submitted to NSLDS. This could include a review of withdrawal or graduation dates compared to the effective dates reported to NSLDS to make sure they are accurate. Action Taken: We have strengthened our procedures for our NSLDS report verification process as we continually strive to comply with all regulations. Once the Ellucian NSC graduation report is run, the Registrar's Office will compare that against at least 10 % of the students on the graduation list to ensure accuracy. There are six times a year that the graduation process occurs. If a student is no longer enrolled but has not completed degree requirements (i.e. takes an incomplete in a course), they would be reported as withdrawn during the next semester. However, once they complete their degree requirements and officially graduate, they will get reported as "graduated" on the next graduation run. Since these students are processed manually, the Registrar's Office will maintain a listing of the "non-traditional graduates" (i.e. finishes degree requirements outside of the six standard times per year) and verify their status is recorded correctly in NSLDS. They will also compare at least 10% of the students on the course drops and withdraw report against the status and date generated by the Ellucian NSC report to ensure accuracy. The Registrar's Office will also realign the NSC reporting schedule for graduating students to align with our processing schedule beginning with the Spring 2024 semester.

View Audit 293677

Finding 372621 (2023-006)

Significant Deficiency 2023

Agate Housing and Services, Inc.

MN

Special Tests & Provisions Eligibility HUD Housing Programs

2023-006 Reasonable Rents Documentation Name of contact person – Laura Straw, Finance Director and/or Elizabeth Machart, Director of Contracts, Compliance, & Special Initiatives Corrective action – Management has reviewed the current practice and has implemented a new form and procedures for do...

2023-006 Reasonable Rents Documentation Name of contact person – Laura Straw, Finance Director and/or Elizabeth Machart, Director of Contracts, Compliance, & Special Initiatives Corrective action – Management has reviewed the current practice and has implemented a new form and procedures for documenting the determination and approvals in the case files. Completion date – Management and the Board of Directors implemented the above as of 2/28/2024

View Audit 293672

Finding 372572 (2023-001)

Significant Deficiency 2023

West Hills Community College District

CA

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

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan Based on the review and assessment of findings, the Financial Aid Office at West Hills College Coalinga will add to their establish policies and procedures an annual check of the reporting mechanism used to...

Management's Response: We concur. View of Responsible Officials and Corrective Action Plan Based on the review and assessment of findings, the Financial Aid Office at West Hills College Coalinga will add to their establish policies and procedures an annual check of the reporting mechanism used to determine “unofficial withdrawals” and update it as needed in coordination with any changes with the Registration system set up. This will help avoid future reporting errors and keep “unofficial withdrawals” determined within the 30-day requirement.

View Audit 293654

Finding 372397 (2023-001)

Significant Deficiency 2023

Boise State University

ID

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.305

Federal Program Title: Research and Development Cluster ALN: Various Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no di...

Federal Program Title: Research and Development Cluster ALN: Various Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Boise State University continues to review and enhance its internal subrecipient payment processes to find ways to identify and prevent untimely subrecipient payments, and to reduce the potential for human error. The University will implement additional internal measures to address inefficiencies related to the current multi-department review, approval, and payment process. Name(s) of the contact person(s) responsible for corrective action: Jen Lutke, Assistant Director, Post Award: jenniferlutke@boisestate.edu Planned completion date for corrective action plan: February 2024

View Audit 293651

Finding 372381 (2023-004)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Student Financial Aid Subrecipient Monitoring Significant Deficiency

GLBA non-compliance Finding: The University does not meet the compliance requirements outlined in the GLBA Safeguards Rule. Discrepancies were identified in requirement B.6 which addresses how the institution how the institution will oversee its information system service providers. The University ...

GLBA non-compliance Finding: The University does not meet the compliance requirements outlined in the GLBA Safeguards Rule. Discrepancies were identified in requirement B.6 which addresses how the institution how the institution will oversee its information system service providers. The University did not have a Vendor Management Program with standards in place to oversee critical system service providers regarding due diligence, risk assessments, and annual reviews as related to 3rd party service providers. Auditors' Recommendation: The University needs to review the updated GLBA requirements and ensure their WISP includes all required elements. School Response: The school agrees with this finding. Corrective Action Plan: The school's director of IT is reviewing the school's Written Information Security Plan (WISP) to ensure GLBA Compliance. A vendor management plan has been added to the WISP which specifies that any information technology vendors and products will be subjected to an IT Acquisition Process prior to use by the University. In the IT Acquisition Process, the vendors and products will be evaluated by the Information Technology Advisory Committee and the Office of Information Technology to determine impact on the current infrastructure and data systems as well as any security concerns that should be addressed prior to implementation. Name(s) of the contact person{s) responsible for corrective action: Point University Director of IT, Bill Dorminy Planned completion date for corrective action plan: • WISP and review of GLBA requirements is ongoing with completion of the current review expected by June 1, 2024.

View Audit 293636

Finding 372380 (2023-003)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Questioned Costs Student Financial Aid Eligibility

Pell Award Errors Finding: As noted in the audit report, there were 5 instances out of 60 students with Pell award errors. Auditors' Recommendation: The University should have appropriate policies and procedure, as well as safeguards in place to ensure Pell eligibility and awarding is correctly de...

Pell Award Errors Finding: As noted in the audit report, there were 5 instances out of 60 students with Pell award errors. Auditors' Recommendation: The University should have appropriate policies and procedure, as well as safeguards in place to ensure Pell eligibility and awarding is correctly determined. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: For student #5, there was a Pell awarding error where the student was under awarded Pell by $172. The school made the correction to the award and disbursed the additional Pell. For student #16, student was over awarded Pell Grant for $1723 due to incorrect refunds made while adjusting for changes in the student's schedule. The school has refunded the $1723 over award back to the fund source. For student #24, the student was initially awarded correctly, but withdrew during their 2nd term. Due to incorrect Pell Recalculation on the R2T4, the school refunded too much Pell grant, and the student was under awarded by $458. The school has disbursed the additional Pell so the student is now paid correctly. For student #27, the student was over awarded Pell by $350 due to in error in Pell Recalculation based on the student's schedule. The school has refunded the over award to the fund source. For student #43, the student was under awarded by $22 due to an error in Pell Recalculation based on the student's schedule. The school has disbursed the additional Pell grant funds to correct the error. Starting with the Fall 2023 semester the school has implemented a new student information system (SIS), Colleague. The school has also partnered with a third-party servicer, Financial Aid Services (FAS), to assist with packaging. The new SIS automatically adjusts Pell grant whenever there is a change to a student's schedule during the term through the school's census date for each term and module. The system will schedule a refund for any over awards and increase the Pell award for any that may have been under awarded. Since this is no longer reviewed solely by the financial aid office, this is expected to reduce the number of errors in Pell awarding. In addition to the system adjustments, the school's third-party servicer, FAS, will review packaging for any students with changes to the number of registered credits during the term to ensure the system is making adjustments properly and the students are correctly packaged. Name(s) of the contact person{s) responsible for corrective action: Financial Aid Director, Holly Hardnett and third-party servicer, FAS, representative Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training for Pell Recalculations in Colleague July 2023. • Registration/schedule changes for term reviewed by FAS at least weekly.

View Audit 293636 Questioned Costs: $1

Finding 372379 (2023-002)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Student Financial Aid Reporting Significant Deficiency

NSLDS Enrollment Reporting (repeat) Finding: As noted in the audit report, there were 4 discrepancies found in 17 files in which student information reported to NSLDS was incorrect or untimely. • 2 students' status was incorrectly reported to NSLDS. • 1 student's enrollment effective date was not r...

NSLDS Enrollment Reporting (repeat) Finding: As noted in the audit report, there were 4 discrepancies found in 17 files in which student information reported to NSLDS was incorrect or untimely. • 2 students' status was incorrectly reported to NSLDS. • 1 student's enrollment effective date was not reported correctly to NSLDS. • 1 student's enrollment status change was not reported to NSLDS within 60 days. Auditors' Recommendation: The University should review their enrollment reporting policies and procedures to ensure accurate reporting. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: There were two files in which NSLDS reporting errors were found. Student #12 was withdrawn per their school transcript effective 5/14/2023, however, the enrollment status was reported at NSLDS as Less Than Half Time as of 5/8/2023. Student #14 was in a Graduate status on their transcript but was reported as Withdrawn on NSLDS. Also, the student's status was reported 134 days after the status change event. Status changes must be reported to NSLDS within 60 days. The instances for this finding occurred during a time when there was a staffing change in the registrar's office and a new registrar had not yet transitioned into the position. Since this time, a new registrar, Natalie Brown-Motes, was hired, and the process has been reviewed with Assistant Registrar, Lara Ellison, to ensure that there is a back up plan if the registrar is unavailable to complete this process. Additionally, the school switched to a new Student Information System (SIS), Colleague, which was implemented beginning with the Fall semester 2023. The new SIS works with the National Student Clearinghouse enrollment reporting service. In order to ensure timely reporting, the registrar's office creates an enrollment report in Colleague each month. That report is transmitted to Clearinghouse which uses the information to update the enrollment data in NSLDS. If there are any possible errors that need to be reviewed, the registrar receives a report on Clearinghouse of any errors so they can be reviewed and approved or corrected. The error report must be completed within two weeks of receipt. Colleague only reports to Clearinghouse students who have actually registered for classes. Previously, enrolled students who had not registered were included in the report. This inclusion regularly generated additional errors. Since the new system improves the reporting process so only registered students are reported, there is less opportunity for error. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Natalie BrownMotes and Assistant Registrar, Lara Ellison Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on National Student Clearinghouse process with Colleague completed September 23. • Began using Colleague system to report enrollment data to NSLDS through National Student Clearinghouse in September 2023.

View Audit 293636

Finding 372378 (2023-001)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Student Financial Aid Reporting Significant Deficiency

Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported t...

Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported to Common Origination and Disbursement (COD). Auditors' Recommendation: The University should review their policies and procedures to ensure accurate reporting to COD. School Response: The University agrees with this finding and has initiated corrective action. Corrective Action Plan: Title IV disbursements must be posted to student accounts within 15 days of the funds drawdown. Also, the disbursement date per COD must match the disbursement date on the student account. There was one instance in which the Disbursement date for a Pell Grant was 10/10/2022 per COD and 10/19/2022 on the student's account. One instance had a disbursement date at COD as 2/16/2023 and at 2/15/2023 on the student's account. The third instance had a disbursement date of 1/25/23 at COD and 1/26/23 on the student's account. Each of these disbursements were posted in the old Student Information System (SIS), Anthology. The posting process that the school used under the previous system relied primarily on manual checks by employees in various departments in which reports could be sent to COD in which the posting dates did not match the COD dates. In order to avoid this finding in the future, the University has sought out and implemented a new Student Information System (SIS), Colleague, beginning with the 2023-24 award year. The school has also contracted with a third-party servicer, Financial Aid Services (FAS}, to assist with packaging students and completing the disbursement process. To disburse funds, the Director of Financial Aid Quality and Compliance or the representative from FAS runs a report in Colleague which pulls scheduled and approved financial aid disbursements for students who have met the enrollment criteria to receive those disbursements. The report goes to the student accounts office where the financial aid is posted to the student ledgers. Then it is transmitted to COD with the posted dates so that the dates reported to COD match the dates in the SIS. If there are any errors in the transmission, the Director of Financial Aid Quality and Compliance or the representative from FAS will review the rejected disbursements and make corrections to get them processed as quickly as possible. The accounting office submits the drawdown request to G-5 for the amount of the approved and posted financial aid. The new process in which the disbursement amounts and dates transmitted to COD match the disbursement amounts and dates posted to the students' ledgers is expected to ensure compliance in the future. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Quality and Compliance, Rachal Wortham Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on new disbursement process completed August 2023. • First disbursements approved using the new SIS done by Director of Financial Aid Quality and Compliance August 2023. • Review of disbursement process with FAS October 2023. • Follow up with Colleague team to review the process and work out any flaws February 2024.

View Audit 293636

Finding 372315 (2023-006)

Significant Deficiency 2023

Dodge City Community College

KS

Student Financial Aid Matching / Level of Effort / Earmarking

Condition: There were no monthly Title IV reconciliations performed. Criteria: Per SFA requirements, the College is required to reconcile the COD data files with the College’s financial records. Cause: Turnover in the staff and Director positions of the College. The new employees were not aware o...

Condition: There were no monthly Title IV reconciliations performed. Criteria: Per SFA requirements, the College is required to reconcile the COD data files with the College’s financial records. Cause: Turnover in the staff and Director positions of the College. The new employees were not aware of this requirement. Effect: Noncompliance with SFA requirements. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. Recommendation: We recommend that the direct loans are reconciled at least monthly between the COD and the College’s general ledger. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved have received training and been made aware of requirements. Monthly reconciliations will be performed immediately.

View Audit 293624

Finding 372314 (2023-005)

Significant Deficiency 2023

Dodge City Community College

KS

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Condition: We examined a sample of Title IV aid recipients to verify that information reported on the Enrollment Reporting roster file sent to the National Student Loan Data System (NSLDS) matched the student's academic files and found instances where students received Title IV aid during a semester...

Condition: We examined a sample of Title IV aid recipients to verify that information reported on the Enrollment Reporting roster file sent to the National Student Loan Data System (NSLDS) matched the student's academic files and found instances where students received Title IV aid during a semester but the status of withdrawn or graduate were not reported correctly or timely on the NSLDS Enrollment Reporting roster files sent during that semester. Criteria: Per the NSLDS Enrollment Reporting Guide, a school should report all students that NSLDS includes in its request to the school on a roster file. This includes timely and accurate reporting of the status of the student of withdrawn or graduate. Cause: The status of the students were not timely and accurately reported to NSLDS. Effect: Students could potentially not be placed in grace or repayment status when they should be. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. They have had interim Director who also left in December 2023. A new Director has been hired in January 2024 and has begun working on issues. Recommendation: We recommend that personnel in charge of enrollment reporting be diligent in reviewing the roster file to ensure that all appropriate students are shown and attendance changes are reported in a timely and accurate manner. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved in enrollment reporting to the NSLDS have reviewed the NSLDS Reporting Manual to better understand and accurately report the student's enrollment status. There has been high turnover in the SFA department, including a time where there was not a Director in place. The new Director came on in the fall of 2022 and then left in December 2023. The College is still working on fully implementing new procedures and catching up submissions.

View Audit 293624

Finding 372299 (2023-002)

Significant Deficiency 2023

Rockhurst University

MO

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

Finding No. 2023-002 Corrective Action Plan: The University concurs with the finding. The Financial Aid office is in the process of tightening its policies and procedures to identify all students subject to the required exit counseling, with the goal of delivering said counseling within the prescrib...

Finding No. 2023-002 Corrective Action Plan: The University concurs with the finding. The Financial Aid office is in the process of tightening its policies and procedures to identify all students subject to the required exit counseling, with the goal of delivering said counseling within the prescribed 30-day window. Responsible Official: John Sircy, Interim CFO Anticipated Completion Date: June 2024

View Audit 293605

Finding 372297 (2023-004)

None 2023

North Dade Senior Citizens Housing Developement Corporation, Inc., Rsi

FL

Questioned Costs HUD Housing Programs Subrecipient Monitoring

FINDING No. 2023-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should improve monitoring of the payroll disbursement process to ensure the appropriate approved wages are paid. Action Taken: Additio...

FINDING No. 2023-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should improve monitoring of the payroll disbursement process to ensure the appropriate approved wages are paid. Action Taken: Additional payroll controls are being evaluated and implemented in 2024. This will include establishing procedures to ensure the completeness and accuracy of payroll and related oversight. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

View Audit 293594 Questioned Costs: $1

Finding 372278 (2023-001)

Significant Deficiency 2023

Sweet Briar Institute

VA

Student Financial Aid Special Tests & Provisions Reporting

Individuals Responsible for Corrective Action Plan Wanda Spradley, Director, Financial Aid Susan Kennon, Registrar Jennifer Sauer, AVP for Finance Corrective Action Plan: The finding is related to required enrollment information being reported to National Student Loan Data System by the registr...

Individuals Responsible for Corrective Action Plan Wanda Spradley, Director, Financial Aid Susan Kennon, Registrar Jennifer Sauer, AVP for Finance Corrective Action Plan: The finding is related to required enrollment information being reported to National Student Loan Data System by the registrar’s office. The errors noted in 2023-001, as well as 2022-001, were primarily related to a lack of internal systems, staff, and expertise in the reporting requirements. A new registrar was hired September 2023, and much work has been done to increase staffing and technology support for the office. The administration is working with the registrar’s office to implement controls to reduce errors and improve timeliness. However, reporting requirements are rigorous, and there will always be challenges. With new systems only recently put in place and the staffing issues continuing in FY23-24, this finding may be noted again next year. Anticipated Completion Date: June 30, 2024

View Audit 293553

Finding 372272 (2023-003)

Significant Deficiency 2023

Northwestern Health Sciences University

MN

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

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: Man...

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: Management agrees with the audit finding where some MPNs are missing. We are unable to correct the past but moving forward, the new ones are being retained. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: September 1, 2023

View Audit 293548

Finding 372227 (2023-001)

Significant Deficiency 2023

Housing Authority of the City of Galveston, Texas

TX

HUD Housing Programs Reporting Significant Deficiency

Housing Choice Vouchers - CFDA No. 14.871 - PIC Reporting Recommendation: The Authority should implement processes to ensure the HUD-50058's are submitted into the PIC system timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...

Housing Choice Vouchers - CFDA No. 14.871 - PIC Reporting Recommendation: The Authority should implement processes to ensure the HUD-50058's are submitted into the PIC system timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HUD-50058 submissions are done daily but there are exceptions where we find that some 50058's submitted do not return as an error later we notice that are not showing in PIC and have to be resubmitted. This has been reported to our field office and the PIC Help Desk with no resolution. Name(s) of the contact person(s) responsible for corrective action: Maria Godwin Planned completion date for corrective action plan: Ongoing

View Audit 293526

Finding 372188 (2023-002)

Significant Deficiency 2023

University of Cincinnati

OH

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding Number: 2023-002 Condition: Out of 60 allowability samples that were tested, one expenditure tested was determined to be incorrectly charged to this grant. Planned Corrective Action: The College of Cooperative Education and Professional Studies (CCPS) has instituted several reforms to prev...

Finding Number: 2023-002 Condition: Out of 60 allowability samples that were tested, one expenditure tested was determined to be incorrectly charged to this grant. Planned Corrective Action: The College of Cooperative Education and Professional Studies (CCPS) has instituted several reforms to prevent future instances of this nature. The Program Director is now required to review and sign-off on all transactions before they are charged to the project, to ensure all charges are appropriate. New staff have been assigned to the project to process transactions, and the CCPS business office is now meeting monthly to review project activity, discuss any questions, and address any concerns regarding financial activities. Additionally, the university is drafting a new policy to review and, if needed, provide additional administrative support for large, complex grant projects. This policy will require that grant proposals above a certain dollar threshold are reviewed by the Office of Research prior to submission to ensure proper resources will be available to manage the project if awarded. In cases where the Office of Research determines additional resources may be needed, they will be authorized to require additional support be included in the grant proposal, or else provide additional administrative help to the unit at the time of award. Contact person responsible for corrective action: CCPS: Jeremy Harvey, Jodi Sleyo, and Bailey Bartels. Office of Research: Patrick Clark Anticipated Completion Date: CCPS changes have been implemented as of 10/11/2023; policy changes to be completed by 6/30/2024.

View Audit 293505 Questioned Costs: $1

Finding 372175 (2023-001)

Significant Deficiency 2023

Montello School District

WI

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

Finding #2023-001 -Limited Segregation of Duties (Prior Year Finding #2022-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected...

Finding #2023-001 -Limited Segregation of Duties (Prior Year Finding #2022-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the district's operations. Response: We agree with this finding and continue to work to achieve segregation of duties whenever cost effective. The cash disbursements process includes approval of purchase orders and matching of approved purchase orders with invoices. Review of account coding is perfo1med by the district accounting staff. The payroll disbursement process includes approval of timesheets and review of coding on an ongoing basis. The Board of Education reviews budget to actual information along with disbursement information monthly.

View Audit 293499

Finding 372135 (2023-001)

Material Weakness 2023

Alameda County Office of Education

CA

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

ACOE updated the new Time and Effort policy and offered agency-wide training.

View Audit 293447 Questioned Costs: $1

Finding 372133 (2023-002)

Material Weakness 2023

Lutheran Community Services Northwest

WA

Matching / Level of Effort / Earmarking Material Weakness Reporting

Finding 2023‐002 Material weakness in internal controls over compliance for earmarking and material noncompliance for earmarking in the U.S. Refugee Admissions Program. Contact Person(s): Nicholas Lee, Chief Financial Officer Corrective action planned: The accounting team will work alongside the pro...

Finding 2023‐002 Material weakness in internal controls over compliance for earmarking and material noncompliance for earmarking in the U.S. Refugee Admissions Program. Contact Person(s): Nicholas Lee, Chief Financial Officer Corrective action planned: The accounting team will work alongside the program management to develop and maintain a client tracker. Monthly meetings will be established to review spend, and resolve any questions. The client tracker will be established for the entire FYE June 30, 2024, and completed by August 31, 2024. The meetings will be established prior to the FYE June 30, 2024. Anticipated completion date: August 31, 2024

View Audit 293446

Finding 372131 (2023-002)

Significant Deficiency 2023

Western New Mexico University

NM

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Enrollment certifications will be sent to the National Student Clearninghouse on a monthly basis, no later than 10 days following the end of the month. The final degree file will be submitted no later than 30 days after the last day of class, with additional awards submitted individually. The Financ...

Enrollment certifications will be sent to the National Student Clearninghouse on a monthly basis, no later than 10 days following the end of the month. The final degree file will be submitted no later than 30 days after the last day of class, with additional awards submitted individually. The Financial Aid Director will review all NSLDS errors.

View Audit 293430

Corrective Action Plans

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