Corrective Action Plans

Finding 11245 (2023-003)

Significant Deficiency 2023

IL

Questioned Costs Subrecipient Monitoring Cash Management § 200.303

Identifying Number: 2023-003 Finding: For 2 out of 17 (11.7%) expenditures tested, portions of the expenditures had service periods that extended beyond the grant’s period of performance and were charged to the grant for reimbursement. Corrective Action Taken or Planned: To prevent a recurrence...

Identifying Number: 2023-003 Finding: For 2 out of 17 (11.7%) expenditures tested, portions of the expenditures had service periods that extended beyond the grant’s period of performance and were charged to the grant for reimbursement. Corrective Action Taken or Planned: To prevent a recurrence, grants transactions will be reviewed by the Principal Investigator/Program Director, the Strategic Advancement unit, and the Finance Office for allowability and alignment with the grant’s performance period. Anticipated Completion Date: This process has already been implemented by the College. Responsible Persons: Nick Branson, Assistant Vice President for Strategic Advancement Jean Stephan, Controller

View Audit 15031 Questioned Costs: $1

Finding 11168 (2023-003)

Significant Deficiency 2023

Fulton County Community Unit School District No. 3

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

Response and corrective action plan: The District will review current processes for identifying, coding, and reporting federal expenditures and implement processes to ensure amounts reported are supported by the District's general ledger.

View Audit 14962

Finding 10952 (2023-001)

None 2023

Harvard University

MA

Student Financial Aid Eligibility Reporting

Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistanc...

Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Federal Pell Grant Program and Federal Direct Student Loans Award Numbers: Not applicable Assistance Listing Titles: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2022-2023 Pass-through entity: Not applicable The enrollment reporting exceptions identified by PwC were isolated to one Harvard school and did not impact the loan repayment status for any student. The exceptions were the result of system reporting and management has completed corrective actions. Program level enrollment effective date was addressed by correcting the enrollment reporting logic within the Harvard school’s reporting system, Ellucian Banner. This updated logic now provides accurate program status effective dates in the National Student Clearinghouse (NSC) reporting file. Harvard successfully transmitted its first file with the updated logic to NSC in November 2023. As program level enrollment data is not used to initiate loan repayment or other loan status changes; these students were not negatively impacted. Withdrawn versus graduation status issue was isolated to off-cycle graduation events in November and March. Although the final status was reported as withdrawn instead of graduated for these selections, there was no impact on the student’s loan repayment or eligibility as we appropriately reported the initial separation event. Harvard implemented a “Graduates Only” NSC reporting file to correctly transmit the graduation status for these off-cycle graduates which will ensure compliance going forward. Sincerely, Amanda McDonnell University Controller 617-495-8032

View Audit 14779

Finding 10932 (2023-003)

Significant Deficiency 2023

Caritas Family Solutions and Affiliates

IL

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

• Corrective Action Plan: Caritas Family Solutions acknowledge the finding and are committed to establishing and enforcing internal control procedures for earmarking compliance requirements. We will work to improve our oversight and compliance in this regard. o A compliance team from the QI Departm...

• Corrective Action Plan: Caritas Family Solutions acknowledge the finding and are committed to establishing and enforcing internal control procedures for earmarking compliance requirements. We will work to improve our oversight and compliance in this regard. o A compliance team from the QI Department will be appointed to ensure that the program adheres to all compliance requirements. o The compliance team will work closely with the PM to coordinate and delegate tasks to determine how and what data will be collected. o The compliance team will work closely with the PM to determine who has responsibility for data entry, compilation, and processing. o The compliance team will assist the program in creating a process for maintaining, storing, and securing data for the required period. o The compliance team will review compliance throughout the life of the grant and adjust, as necessary. • Anticipated Completion Date: The process will be implemented on January 3, 2024, and will be continually updated to align with best practices.

View Audit 14751

Finding 10920 (2023-001)

Significant Deficiency 2023

University of New Mexico

NM

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

Corrective Action Plan: Currently, UNM sends award information upon initial packaging which includes type of loan offered, if any, amount, and semester. The packaging process typically begins in March for the following aid year and runs on a nightly basis. A separate loan offer notification is sent ...

Corrective Action Plan: Currently, UNM sends award information upon initial packaging which includes type of loan offered, if any, amount, and semester. The packaging process typically begins in March for the following aid year and runs on a nightly basis. A separate loan offer notification is sent upon packaging which includes type of loan offered, amount, and semester. The loan offer also includes instructions on how to accept the loan and links to resources such as loan interest rates, promissory notes, entrance counseling and how to access loan history via NSLDS. If students choose to accept the loan(s), a loan acceptance notification is sent. This notification includes type of loan, amount, and semester. It also includes right to cancel information, cancellation procedures and instructions on accessing loan history. Loan acceptance notifications are sent nightly upon acceptance. The timing of the loan offer and acceptance notifications is based on when the student completes their financial aid file and is packaged, and when they accept their loan(s) but does not correspond with the actual loan disbursement. UNM has been relying on the loan offer and acceptance notifications and COD disbursement notifications to convey the loan disbursement notification information as required per 34 CFR 668.165. Effective immediately, UNM will establish an internal process to send loan disbursement notifications within 30 days of the actual loan disbursement. The internal process will duplicate our current offer and acceptance notifications. UNM will continue to opt in to COD disbursement notifications as a secondary method of communication. Contact Person: Elizabeth Jacquez-Amador Anticipated Completion Date: October 31, 2023

View Audit 14747

Finding 10914 (2023-002)

Material Weakness 2023

Three Rivers Community Schools

MI

Matching / Level of Effort / Earmarking

Condition: The School District tracked employee activities through the use of schedules and semi-annual certifications but did not have adequate controls in place to ensure these personnel activity reports/certifications were reviewed timely and accurately. During payroll expenditure testing of s...

Condition: The School District tracked employee activities through the use of schedules and semi-annual certifications but did not have adequate controls in place to ensure these personnel activity reports/certifications were reviewed timely and accurately. During payroll expenditure testing of salaried employees, it was identified that, for employees who spend time in multiple cost objectives, appropriate controls were not in place to perform a timely reconciliation between the time charged to Title I based on budget estimates and the actual time expended on Title I activities. Planned Corrective Action: Three Rivers Community Schools agrees with the above recommendation. While the proper controls were not in place throughout the year, the School District changed their procedures and controls near year-end to allow for a review and reconciliation process to support that the amount charged to Title I based on actual time expended on Title I activities. Contact person responsible for corrective action: Angie Tesman, Director of Business Operations Anticipated Completion Date: 11/7/2023

View Audit 14719

Finding 10884 (2023-001)

Significant Deficiency 2023

Gavilan Joint Community College District

CA

Student Financial Aid Special Tests & Provisions Reporting

Gavilan’s current process in submitting enrollment files to NSC involves a collaboration between two departments: Admissions and Records and Information Technology. During this period, primarily in Spring 2023, the two parties experienced a miscommunication between which file contained the current e...

Gavilan’s current process in submitting enrollment files to NSC involves a collaboration between two departments: Admissions and Records and Information Technology. During this period, primarily in Spring 2023, the two parties experienced a miscommunication between which file contained the current enrollment data versus which file was being submitted to NSC. Admissions and Records mistakenly submitted 4 incorrect files. Since, Admissions and Records has worked with IT to update procedures and strengthen communication when collecting the current enrollment data. To further correct the deficiency, discussions circled around Admissions and records working with a Banner Ellucian Consultant to review our Banner capabilities and strengthen the user control to oversee and submit the enrollment reports independent of IT’ s assistance. Admissions and Records will also develop a written manual to cover the step-by-step process in submitting the School Enrollment Transmission to National Student Clearinghouse in order for the correct NSLDS monitoring. The written manual will document: • Banner pages and strokes, including screen shots. • Current IT process, point of contact and ﬁle name • Link to future transmission page on the Na1onal Student Clearinghouse user page • Link to NSDLS Repor1ng page to validate and conﬁrm correct submissions have been reported. The Director of Admissions and Records will coordinate business practices with Admissions and Records, Financial Aid and IT to ensure the school enrollment transmissions are submitted on time and are correct. The business process will be documented by Admissions and Records and shared with Financial Aid, IT, and the VP of Student Services

View Audit 14642

Finding 10836 (2023-011)

Significant Deficiency 2023

Washoe County

NV

Reporting Student Financial Aid Significant Deficiency

Date: 12/26/2023 Division: Human Services Agency Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-011 Finding: The Washoe County Human Services Agency (HSA) did not have adequate internal controls to ensure the amounts reported on the quarterly CB-496 reports...

Date: 12/26/2023 Division: Human Services Agency Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-011 Finding: The Washoe County Human Services Agency (HSA) did not have adequate internal controls to ensure the amounts reported on the quarterly CB-496 reports agreed to underlying supporting records. Corrective Action Taken or To Be Taken: Notify DCFS partner of incorrect submission. Reviewed proper process with cost allocation team. Expanded and strengthened QA process for client count submissions. If already taken, date of completion: 8/14/2023 If to be taken, estimated date of completion: Agency Response Does the Agency Agree with finding?: Yes ☒ No ☐ Partially ☐ If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Pamela Mann Address or Mailstop: 350 S. Center St. City, State, Zip Code: Reno, NV 89501 Phone Number: 775-685-6698 Email: pmann@washoecounty.gov Reviewed and Approved December 26, 2023 Signature Date:

View Audit 14489

Finding 10822 (2023-010)

Significant Deficiency 2023

Washoe County

NV

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles

Date: 12/26/2023 Division: Human Services Agency Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-010 Finding: Some expenditures reported did not agree to underlying supporting documentation. The Office of the County Manager did not have internal controls est...

Date: 12/26/2023 Division: Human Services Agency Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-010 Finding: Some expenditures reported did not agree to underlying supporting documentation. The Office of the County Manager did not have internal controls established over the review of Quarterly Compliance Reports. Corrective Action Taken or To Be Taken: Internal controls to be established to include the review of Quarterly Compliance Reports. If already taken, date of completion: If to be taken, estimated date of completion: January 2024 Agency Response Does the Agency Agree with finding?: Yes 􀜈 No 􀜆 Partially 􀜆 If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Dana Searcy, Division Director Address or Mailstop: 170 S. Virginia Street, Suite 201 City, State, Zip Code: Reno, NV 89501 Phone Number: 775-325-8210 Email: dsearcy@washoecounty.gov Reviewed and Approved Cathy HillDigitally signed by Cathy Hill Date: 2023.12.27

View Audit 14489

Finding 10821 (2023-009)

Material Weakness 2023

Washoe County

NV

Internal Control / Segregation of Duties Eligibility Material Weakness

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-009 Finding: The Office of the County Manager did not have internal controls established over the determination of eligibility of the participants in the ...

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-009 Finding: The Office of the County Manager did not have internal controls established over the determination of eligibility of the participants in the Emergency Rental Assistance Program. Corrective Action Taken or To Be Taken: Internal controls will include determining the eligibility of the participants in the Emergency Rental Assistance Program. If already taken, date of completion: If to be taken, estimated date of completion: January 2024 Agency Response Does the Agency Agree with finding?: Yes 􀜈 No 􀜆 Partially 􀜆 If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Cathy Hill, Comptroller Address or Mailstop: 1001 E. Ninth St. City, State, Zip Code: Reno, NV 89512 Phone Number: (775) 328-2552 Email: chill@washoecounty.gov Reviewed and Approved Cathy HillDigitally signed by Cathy Hill Date: 2023.12.27

View Audit 14489

Finding 10820 (2023-008)

Material Weakness 2023

Washoe County

NV

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-008 Finding: The Office of the County Manager did not have internal controls established over the direct payments made to participants of the Emergency Re...

Date: 12/27/2023 Division: Office of the County Manager Corrective Action Plan Audit Report Number: Year ended June 30, 2023 Finding Number: 2023-008 Finding: The Office of the County Manager did not have internal controls established over the direct payments made to participants of the Emergency Rental Assistance Program. Corrective Action Taken or To Be Taken: Internal controls will be monitored/created for future awards. If already taken, date of completion: If to be taken, estimated date of completion: January 2024 Agency Response Does the Agency Agree with finding?: Yes 􀜈 No 􀜆 Partially 􀜆 If No or Partial, Please explain reason(s) why: Additional Comments: Division Responsible for Corrective Action Plan Name, Title: Cathy Hill, Comptroller Address or Mailstop: 1001 E. Ninth St. City, State, Zip Code: Reno, NV 89512 Phone Number: (775) 328-2552 Email: chill@washoecounty.gov Reviewed and Approved Cathy HillDigitally signed by Cathy Hill Date: 2023.12.27

View Audit 14489

Finding 10815 (2023-001)

None 2023

Way Finders, Inc. and Subsidiaries

MA

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

2023-001 Payments on behalf of Ineligible Participants Responsible Official Janette Vigo, Chief Program Officer Plan Detail Although we currently have strong processes in place to flag and identify most ineligible payments before they are made, Way Finders will continue our work internally to d...

2023-001 Payments on behalf of Ineligible Participants Responsible Official Janette Vigo, Chief Program Officer Plan Detail Although we currently have strong processes in place to flag and identify most ineligible payments before they are made, Way Finders will continue our work internally to determine and implement additional measures as recommended by the Executive Office of Housing and Livable Communities (EOHLC). We will hire an independent firm to perform a programmatic audit including a review of any applications processed using manual system overrides. We will request that EOHLC tighten access for all users and limit override abilities solely to the compliance team. We will also implement a monthly review of all overrides in the system to proactively evaluate potential risks within the system to prevent similar ineligible payments. Additionally, management has established a Fraud Risk Oversight Committee (FROC) whose members are the CEO, CFO, Chief Legal Officer, Chief Program Officer, and SVP of Housing Education Services. The FROC will oversee the implementation of the corrective action plan and report on a quarterly basis to the Board of Directors, Finance and Audit Committee. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in fiscal year 2024.

View Audit 14465 Questioned Costs: $1

Finding 10807 (2023-001)

Significant Deficiency 2023

Piedmont University

GA

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

Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their written information security program (WISP) includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit find...

Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend that the College review the updated GLBA requirements and ensure their written information security program (WISP) includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: Non-compliance with GLBA Action taken in response to finding: Management has already taken action and developed a written information security plan and will implement the written policy that includes all the required elements. Name(s) of the contact person(s) responsible for corrective action: Brant Wright Planned completion date for corrective action plan: December 31, 2023

View Audit 14454

Finding 10693 (2023-001)

Significant Deficiency 2023

Town of Woodbridge

CT

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

The Town will adopt a formal policy to document and identify suspended and disbarred vendors and review the System for Award Management (SAM) for such vendors before engaging with a vendor in a project that uses federal funds including ARP funds. We will document, with email and other evidence, that...

The Town will adopt a formal policy to document and identify suspended and disbarred vendors and review the System for Award Management (SAM) for such vendors before engaging with a vendor in a project that uses federal funds including ARP funds. We will document, with email and other evidence, that such steps have been taken.

View Audit 14412

Finding 10675 (2023-002)

Significant Deficiency 2023

Mercedes Independent School District

TX

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.326

Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer ...

Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer will implement a new Vendor Contract Packet. The Vendor Contract Packet will consist of an EDGAR Certification Form that will address the assurances under the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR 200 (EDGAR). Within the vendor packet, will be the vendor’s agreement and ability to comply with EDGAR regulations. Further, it will require the vendor to agree to the wage rate determinations and a copy of the certified payrolls and a statement of compliance with requirement. Contact person: Sylvia S. Garza, CFO Completion: January 31, 2024

View Audit 14352

Finding 10670 (2023-001)

Significant Deficiency 2023

Mercedes Independent School District

TX

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.326

Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer ...

Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer will implement a new Vendor Contract Packet. The Vendor Contract Packet will consist of an EDGAR Certification Form that will address the assurances under the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR 200 (EDGAR). Within the vendor packet, will be the vendor’s agreement and ability to comply with EDGAR regulations. Further, it will require the vendor to agree to the wage rate determinations and a copy of the certified payrolls and a statement of compliance with requirement. Contact person: Sylvia S. Garza, CFO Completion: January 31, 2024

View Audit 14352

Finding 10659 (2023-002)

Material Weakness 2023

Marshall Public Schools

MI

Questioned Costs Special Tests & Provisions Procurement, Suspension & Debarment

Finding: 2023-002 – Special Tests and Provisions – Wage Rate Requirements U.S. Department of Education – COVID-19 - Education Stabilization Fund (ALN 84.425D and 84.425U); Passed through the Michigan Department of Education; All project numbers. Auditor Description of Condition and Effect: Three o...

Finding: 2023-002 – Special Tests and Provisions – Wage Rate Requirements U.S. Department of Education – COVID-19 - Education Stabilization Fund (ALN 84.425D and 84.425U); Passed through the Michigan Department of Education; All project numbers. Auditor Description of Condition and Effect: Three of the contracts selected for testing that were subject to the Wage Rate Requirements did not include the required provision, and the District did not obtain the required certified payrolls. The District did not follow federal requirements to include the prevailing wage rate provision in its contract. Auditor Recommendation: We recommend that the District reviews its policies to ensure that applicable prevailing wage requirements are included in construction contracts whenever federal funds are used and certified payrolls are obtained. Corrective Action: District officials will ensure that construction contracts contain these requirements during the bidding and/or proposal process. Responsible Person: Rebecca Jones, Superintendent and Tara Newman, Business Manager Anticipated Completion Date: June 30, 2024

View Audit 14327 Questioned Costs: $1

Finding 10633 (2023-001)

Significant Deficiency 2023

Brewton-Parker College

GA

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

Finding 2023-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 3 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College rev...

Finding 2023-001: Special Tests and Provisions: Enrollment Reporting Context/Condition: Of the 40 students selected for enrollment reporting testing, 3 students within the sample were reported to NSLDS outside the maximum 60-day window. Recommendation: The auditor recommended that the College review and update internal controls to ensure student enrollment status in the National Student Loan Data System (NSLDS) is updated in a timely manner to ensure compliance with Federal requirements. Persons Responsible for Corrective Action: Dr. Deokhyo Kim, Registrar Planned Corrective Action: We communicated with our software vendor, Aptron, to determine what caused the enrollment reporting issues. We identified two issues and worked with Aptron to put measures in place so that these issues do not happen in the future. 1. Missing withdrawn students who were not pulled up by system when they withdrew before or on the 1st enrollment report date. APTRON fixed the programming and the system now pulls those who are withdrawn before or on the 1st enrollment report date for each semester. 2. Missing graduates with their 2nd degree. APTRON fixed the programming, so that our Degree Verify file will now report a student who has earned a second degree with us. A Degree Verify File of graduates was submitted to the NSCH for any student who had earned a second degree not previously reported. Anticipated Completion Date: Fixes with our software vendor have been completed.

View Audit 14308

Finding 10499 (2023-002)

Significant Deficiency 2023

Payne Theological Seminary

OH

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

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The seminary will update our current WISP to comply with additional requirements and newer standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram, Director of Finance Planned completion date for corrective action plan: February 1,2024

View Audit 14195

Finding 10498 (2023-001)

Significant Deficiency 2023

Payne Theological Seminary

OH

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

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to ensure timely reporting as well as put a process in place to ensure the enrollment effective date reported to NSLDS is aligning with the Seminary's last date of attendance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Seminary will continue to use the import / export function to report to NSLDS. Financial Aid Services will reiew the report, prior to submission, for any errors, duplications, etc. Name(s) of the contact person(s) responsible for corrective action: Maryjo Lewis, Registar Planned completion date for corrective action plan: January 1,2024

View Audit 14195

Finding 10472 (2023-002)

Significant Deficiency 2023

Mt. Hood Community College

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

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