Corrective Action Plans

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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.
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
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.
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.
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
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
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
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
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
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
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
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.
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.
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
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
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
Finding 10253 (2023-009)
Significant Deficiency 2023
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
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
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
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
Finding Number: 2023-005 Approval Of Expense Transactions Corrective Action Plan: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grant...
Finding Number: 2023-005 Approval Of Expense Transactions Corrective Action Plan: A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2024
Finding Number: 2023-004 and 2022-005 – Review and Approval of the Schedule of Expenditures of Federal Awards (SEFA) Corrective Action Plan: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/r...
Finding Number: 2023-004 and 2022-005 – Review and Approval of the Schedule of Expenditures of Federal Awards (SEFA) Corrective Action Plan: While there was a review of the SEFA, the documentation of said review did not occur properly. Management has put in place a process to document preparation/review of the SEFA evidenced by signature and date. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2024
Criteria: The funds set aside for debt service reserve are to be used to make USDA loan payments, but must be approved by the USDA before they can be used. Condition: During our review of compliance requirements for the Community Facilities Loans & Grants Cluster, we identified funds were used durin...
Criteria: The funds set aside for debt service reserve are to be used to make USDA loan payments, but must be approved by the USDA before they can be used. Condition: During our review of compliance requirements for the Community Facilities Loans & Grants Cluster, we identified funds were used during the year for operational purposes and did not ask or receive permission from the USDA to use the funds. Cause: The requirement was not met due to an oversight of management. Potential Effect: As a result, the Agency reserves the right to withdraw Agency funding. Recommendation: The Organization should request permission before using reserve funds. Client Response: The Organization will request permission in the future.
Criteria: The Organization is required to submit complete and accurate quarterly financial statements within 20 days of the quarter end, the annual budget must be submitted to the Agency 30 days prior to the beginning of the borrower's fiscal year, and audit report within 150 days of borrower's fisc...
Criteria: The Organization is required to submit complete and accurate quarterly financial statements within 20 days of the quarter end, the annual budget must be submitted to the Agency 30 days prior to the beginning of the borrower's fiscal year, and audit report within 150 days of borrower's fiscal year end. Condition: During our review of compliance requirements for the Community Facilities Loans & Grants Cluster, we identified the quarterly financial statements were not submitted timely for the second quarter of 2023, third quarter of 2023, and fourth quarter of 2023, the annual budget was not submitted timely, and the 6/30/22 audit report was not submitted. Cause: The submission of timely and complete reports was not met due to turnover in the administrator position. Potential Effect: As a result, the Agency reserves the right to withdraw Agency funding. Recommendation: The Organization should implement reminders and additional review to ensure the quarterly reports, annual budget, are submitted timely, are complete, and are accurate. Client Resronse: The Organization will be diligent to get the reports submitted on time and accurately. All reports except the budget have been submitted as of report date.
Criteria: The funds set aside for debt service reserve are to be used to make USDA loan payments, but must be approved by the USDA before they can be used. Condition: During our review of compliance requirements for the Community Facilities Loans & Grants Cluster, we identified funds were used durin...
Criteria: The funds set aside for debt service reserve are to be used to make USDA loan payments, but must be approved by the USDA before they can be used. Condition: During our review of compliance requirements for the Community Facilities Loans & Grants Cluster, we identified funds were used during the year for operational purposes and did not ask or receive permission from the USDA to use the funds. Cause: The requirement was not met due to an oversight of management. Potential Effect: As a result, the Agency reserves the right to withdraw Agency funding. Recommendation: The Organization should request permission before using reserve funds. Client Response: The Organization will request permission in the future.
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