Corrective Action Plans

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The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was n...
The following is the Recruitment and Admissions Corrective Action Plan for the single Audit Finding for FY25. Criteria or Specific Requirement: Special Tests and Provisions – NSLDS Reporting, 34 CFR Sections 690.83 (b)(2) and 685.309. Finding Summary: Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately. Officials Responsible for Ensuring Corrective Action: Shanna Pope, Registrar Views of Responsible Officials and Planned Corrective Action: Management concurs with the finding and will implement enhanced procedures to ensure internal controls support the timely and accurate reporting of student status, program, and completion information to the National Student Loan Data System (NSLDS). For each National Student Clearinghouse (NSC) file submitted, students with status, program, or completion changes will be systematically identified and flagged for review. Registrar staff will conduct a targeted, sample-based review of these flagged records directly within NSLDS to verify that data transmitted from NSC was received, processed, and reflected accurately. All policies and procedures governing enrollment reporting and the processing of student status, program, and completion changes will be reviewed, revised as necessary, and formally implemented no later than April 1, 2026, to align with this corrective action.
Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management ...
Procedures are currently in place to comply with the requirement to send Direct Loan notifications within the regulatory time frame. To support this, the responsible team member will have a weekly reminder added to their Lewis & Clark Outlook work calendar to prompt timely notifications. Management will also add a weekly reminder to one of the office managers' calendars to assist with ongoing monitoring and compliance checks. Person(s) Responsible: Angela Weaver Timing for Implementation: November 7, 2025
The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the ...
The Financial Aid office conducted a comprehensive internal review in Spring 2025 to verify that our procedures were consistently followed. As a result, management corrected a student’s loan proration calculation to be consistent with current practices, regarding truncating rather than rounding the fractional percentage (decimal) of loan eligibility for students receiving one-semester loans in their last semester of study. Management corrected the loan proration calculation in accordance with current procedures, and the loan amount was adjusted accordingly, resulting in the institution returning $64 in Federal Unsubsidized loan funds to Federal Student Aid. The student was eligible only for unsubsidized loans. Person(s) Responsible: Angela Weaver Timing for Implementation: November 21, 2025
We have carefully reviewed the finding of Documentation of Internal Controls over Federal Awards. The City of Central concurs with the finding. City management recognizes the importance of maintaining current, comprehensive, and properly documented internal controls over federal awards in accordance...
We have carefully reviewed the finding of Documentation of Internal Controls over Federal Awards. The City of Central concurs with the finding. City management recognizes the importance of maintaining current, comprehensive, and properly documented internal controls over federal awards in accordance with 2 CFR part 200.303(a). The City acknowledges that while formal policies and procedures existed, they were not fully updated to reflect current Uniform Guidance requirements and did not sufficiently address all applicable compliance areas for the federal programs administered. The City will undertake a comprehensive review of its existing policies and procedures. Management will update and formalize internal control documentation over federal awards to ensure alignment with Uniform Guidance requirements and to address all relevant compliance areas applicable to the City’s federal programs. This process will include identifying key control activities, documenting responsibilities, and ensuring controls are properly designed and implemented. Additionally, management will increase awareness of Uniform Guidance requirements and internal controls documentation standards by providing resources to applicable staff. Management will continue to periodically review internal control documentation to ensure continued compliance as federal requirements change. Responsible Officials: Mayor Wade Evans; Suzonne Cowart, CPA; Michele Lobianco Anticipated Completion Date: February 2026
1. Immediate Compliance Review and Documentation Grants Accounting & Grants Development and Compliance (GDC) will conduct a comprehensive review of the five HEIA grants renewed for FY2026: • Verify each employee's current compensation source (institutional vs. grant funds) • Calculate the correct gr...
1. Immediate Compliance Review and Documentation Grants Accounting & Grants Development and Compliance (GDC) will conduct a comprehensive review of the five HEIA grants renewed for FY2026: • Verify each employee's current compensation source (institutional vs. grant funds) • Calculate the correct grant-funded compensation based on Level of Effort percentages • Determine the period of noncompliance for each grant • Document total amount of personnel costs that should have been charged to grants • Make adjusting entries in FY2026 as needed 2. Transition Personnel to Grant-Funded Payroll (if required) Grants Accounting will work with the Program Team to: • Establish split-funding arrangements for each affected employee based on their Level of Effort • Update payroll accounting codes to properly charge personnel costs to grant accounts • Ensure proper fund availability and budget alignment 3. Review Time and Effort Reporting Procedures and Update (if necessary) Establish compliant time and effort documentation as required by 2 CFR 200.430: • For employees working solely on one grant (100% effort): Implement semi-annual certification • For employees on multiple cost objectives: Review time and effort documentation to ensure proper payroll allocation; correct as needed • Re-train all affected personnel on time and effort reporting requirements • Establish quarterly review process to ensure accurate reporting 4. Budget Realignment and Prior Approval Requests For each affected grant: • Review current budget vs. actual expenditures • Determine if budget modifications are needed to accommodate personnel costs • Submit prior approval requests to Department of Education if required (2 CFR 200.308) • Coordinate with program officers for each grant as needed 5. Policy and Procedure Updates Develop and implement enhanced procedures to prevent recurrence: • Update standard operating procedures for setting up grant-funded positions • Establish pre-award checklist requiring coordination between Grants Office and HR • Implement quarterly reconciliation between GAN key personnel and actual payroll charges • Require GDC to sign-off on all personnel appointments for grant-funded positions • Update training and grant orientation information as needed 6. Training and Communication Provide comprehensive training to: • All current Project Directors/Managers on federal grant personnel requirements • HR staff on grant-funded position management • Grants Accounting staff on proper cost allocation and monitoring • Department chairs/supervisors who oversee grant-funded personnel 7. Ongoing Monitoring and Quality Assurance Implement enhanced monitoring procedures: • Monthly reconciliation of GAN key personnel vs. actual grant charges • Quarterly review of time and effort reports for completeness and accuracy • Annual internal review of grant personnel compliance 8. Communication with Federal Agencies As appropriate: • Submit required modifications or amendments to grant agreements • Provide documentation of compliance restoration
2025-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027 Special Education Preschool Grants ALN: 84.173 Condition: Subpart I, 2 CFR §200.4...
2025-001. Payroll (Allowable Costs/Cost Principles) United States Department of Education, Passed-through New York State Department of Education: Special Education Cluster Special Education Grants to States ALN: 84.027 Special Education Preschool Grants ALN: 84.173 Condition: Subpart I, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employees work on more than one Federal award, or a Federal award and non-Federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, it was noted that in some instances, the District’s PARs were not signed by the employees. In addition, PARs for employees not charged 100% to a single grant were prepared retrospectively after year end rather than periodically throughout the year. Planned Corrective Action: PARS’s were sent to all employees on a bi-monthly basis beginning October 31, 2025. PAR’s that were not returned in a timely manner with signature were sent to the employee’s supervisor directly to obtain signature. Responsible Contact Person: Keri Loughlin Assistant Superintendent for Finance and Operations Bayport-Blue Point Union Free School District 189 Academy Street Bayport, New York 11705 Anticipated Completion Date: October 31, 2025
The City will implement procedures to ensure that all current year expenditures related to federal awards are accurately recorded on the SEFA and properly reconciled to the General Ledger.
The City will implement procedures to ensure that all current year expenditures related to federal awards are accurately recorded on the SEFA and properly reconciled to the General Ledger.
Condition: All grant fund expenditures should be posted to and accounted for in the general ledger accounts separate from other district expenditures. Wages that were paid with grant funds were not posted to separate grant general ledger accounts. Recommendation: We recommend steps are taken to esta...
Condition: All grant fund expenditures should be posted to and accounted for in the general ledger accounts separate from other district expenditures. Wages that were paid with grant funds were not posted to separate grant general ledger accounts. Recommendation: We recommend steps are taken to establish additional IDEA grant accounts for the purposes of tracking payroll expenditures billed to the grant. We also recommend implementing a detailed grant tracking sheet that would add another level of reconciliation between the quarterly reports to ISBE and the general ledger data. Management Response: The District will consider the implementation of additional grant accounts and a detailed grant tracking sheet. Anticipated Date of Completion: June 30, 2026
The institution implemented adequate oversight to ensure the dates and the student information match NSLDS. To achieve this, the institution has started following up every NSLDS report-run with monitoring to visually confirm the correct data shows up in NSLDS within the required timeframe. The insti...
The institution implemented adequate oversight to ensure the dates and the student information match NSLDS. To achieve this, the institution has started following up every NSLDS report-run with monitoring to visually confirm the correct data shows up in NSLDS within the required timeframe. The institution will keep documentation of the audits and will audit 100% of the records until confidence is gained that the process is working and NSLDS reporting is compliant.
The City will work on a formal process for tracking all federal grants so that the reported federal expenditures are accurate.
The City will work on a formal process for tracking all federal grants so that the reported federal expenditures are accurate.
View of Responsible Officials and Planned Corrective Actions: The Center concurs with the finding. We acknowledge that our current accounting systems are outdated and lack the functionality required to support accurate and efficient expense allocations. We are in the final stages of selecting a new ...
View of Responsible Officials and Planned Corrective Actions: The Center concurs with the finding. We acknowledge that our current accounting systems are outdated and lack the functionality required to support accurate and efficient expense allocations. We are in the final stages of selecting a new accounting system that which enhance our financial reporting capabilities and improve allocation accuracy. In the interim, the Center has implemented manual procedures to mitigate the risk of misallocations. Specifically, credit card purchases are now being manually entered into the general ledger to ensure each transaction is accurately matched to its corresponding receipt. This process provides greater transparency and reduces the likelihood of erroneous allocations. Additionally, we continue to utilize our Purchase Order process, which requires pre-approval by management for all purchases. This control ensures that expenditures are authorized and properly aligned with program objectives prior to being incurred. These interim measures, combined with our upcoming system upgrade, are intended to strengthen our internal controls and ensure that expenses charged to Federal awards are allocable in accordance with 2 CFR § 75.405.
FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA)- Earmarking Summary of Finding: The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2023-2024, the Cooperative operated the special education programs and s...
FINDING 2025-002 Finding Subject: Special Education Cluster (IDEA)- Earmarking Summary of Finding: The School Corporation is a member of the Greater Lafayette Area Special Services Cooperative (Cooperative). During fiscal years 2023-2024, the Cooperative operated the special education programs and spent the federal money on behalf of all of its members. As the grant agreements were between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. However, there was inadequate oversight performed by the School Corporation in order to ensure compliance with the Matching, Level of Effort, Earmarking compliance requirement. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the earmarking requirements. The Cooperative did not have adequate procedures in place to ensure that the required level of expenditures for nonpublic school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure nonpublic school expenditures were appropriately identified and reported. The Non-Public Proportionate Share expenditures for the 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, and 23619-021-PN01 grant awards could not be verified for the individual member schools. Total grant expenditures were posted as expended. The nonpublic proportionate share expenditures were determined by applying a percentage to the nonpublic school budgeted expenditures. As such, we were unable to identify if the minimum amount per the grant awards was expended and properly reported to the IDOE as required. The lack of internal controls and noncompliance were isolated to the 22611-021-PN01, 22611-021-ARP, 22619-021-ARP, 23611-021-PN01, and 23619-021-PN01 grant awards. Contact Person Responsible for Corrective Action: Lissa Stranahan Contact Phone Number and Email Address: (Phone) 765-771-6013 (Email) lstranahan@lsc.k12.in.us Views of Responsible Officials: We concur with the finding. The Greater Lafayette Area Special Services (GLASS)and Local Education Agency, Lafayette School Corporation, concur with the audit finding for Earmarking. GLASS did not have adequate procedures in place to ensure that the required level of expenditures for non-public school students with disabilities was met for each member school. The Cooperative did not have effective internal controls to ensure non-public school expenditures were appropriately identified and reported. The methodology used by the Cooperative to monitor non-public proportionate share expenditures was based upon a percentage for each school corporation that comprises the Cooperative rather than basing the expenditures off of the grant award for each non-public school within the geographical boundaries of the school corporations. While all proportionate share funds were expended, it was problematic in determining if the minimum amount per the grant awards was expended and properly reported prior to July 1, 2024. INDIANA STATE BOARD OF ACCOUNTS 28 Description of Corrective Action Plan: The former Director of GLASS retired June 30, 2023. Upon hire on July 1, 2023, the new director immediately implemented measures to correct the previous methodology used at GLASS. Non-public proportionate share funds are identified and reported based upon the grant award for each school corporation. The expenditures are based upon the geographical location of the non-public school and the corresponding public school corporation, not based upon the “home” school corporation of the student. This process was implemented and descriptions were included on the ledgers to identify non-public school proportionate share for grants that were initiated during the FY 2024-2025 school year. Anticipated Completion Date: The corrective action was already put into place on July 1, 2023 and implemented with FY 2024-2025. The audit finding reflects the previous grant cycle for 2022 grants and 2023 grants, which is prior to this action taken.
HIV Formula Care Grant (AL93.917) - Significant Deficiency 2025-001 Management agrees with the finding and will enhance the current processes. Subsequent to year end, management created a tool to ensure all elements of program income, as well as related expenses incurred, are properly tracked, repor...
HIV Formula Care Grant (AL93.917) - Significant Deficiency 2025-001 Management agrees with the finding and will enhance the current processes. Subsequent to year end, management created a tool to ensure all elements of program income, as well as related expenses incurred, are properly tracked, reported, and utilized in accordance with federal requirements. Additionally, written policies are being drafted to reflect these procedures. Implementation is expected by January 31, 2026.
Corrective Action Plan: To incorporate both the City Finance Department as well as a new Grant Writer position hired earlier this year, the City will update its internal control policy as it pertains to grant reimbursements. The City will define a workflow to allow for opportunities for the Grant Wr...
Corrective Action Plan: To incorporate both the City Finance Department as well as a new Grant Writer position hired earlier this year, the City will update its internal control policy as it pertains to grant reimbursements. The City will define a workflow to allow for opportunities for the Grant Writer and Finance to review draw requests prior to submission for reimbursement, especially for those grants with matching requirements. This workflow will include a checklist of required items, to include an accurate accounting of the required match, as well as signature lines for approval.
staff will work with the auditors to ensure that the single audit report is submitted to the federal clearing house in a timely manner
staff will work with the auditors to ensure that the single audit report is submitted to the federal clearing house in a timely manner
Finding 2025-001: Incorrect Federal Direct Loan Amounts – the auditor tested seventy-one files, sixty-seven of which were Federal Direct Loan recipients, and two students received incorrect loan amounts. It is recommended that the Institution refund $237 to the Department of Education and increase c...
Finding 2025-001: Incorrect Federal Direct Loan Amounts – the auditor tested seventy-one files, sixty-seven of which were Federal Direct Loan recipients, and two students received incorrect loan amounts. It is recommended that the Institution refund $237 to the Department of Education and increase controls over packaging direct loans. There is no action required for the $333 in underawarded subsidized loans, as the student is no longer a current student, so the Institution is unable to reclassify the loans. Comments on Finding and Recommendation(s): This was an oversight on previous FA advisor when prorating loans. Actions Taken or Planned: Employee was removed from role earlier in the year and intense training has been given to the replacement. All debts have been settled with the Department of Education and appropriate student ledgers updated.
Identifying Number: 2025-001 Finding: The Foundation and College did not timely refund a student’s credit balance. Contact person responsible for corrective action: Laura Reagan, Senior Director of Financial Affairs Corrective Actions Taken or Planned: The Student Billing system omitted the student ...
Identifying Number: 2025-001 Finding: The Foundation and College did not timely refund a student’s credit balance. Contact person responsible for corrective action: Laura Reagan, Senior Director of Financial Affairs Corrective Actions Taken or Planned: The Student Billing system omitted the student from the original refund list due to an inactive address in the system. The credit balance was identified on a routine review of the student billing aging report and subsequently processed. It was completed outside of the 14 day requirement. A process will be put in place to increase the frequency of the aging review to ensure any missed credit balances will be processed within the required time frame. Anticipated Completion date: June 30th, 2026
Managemet acknowledges they were not in compliance with the financial covenants ofthe bond. Management has been in contact USDA to keep them informed on thesituation and has put plans into place to improve the financial position of the District.
Managemet acknowledges they were not in compliance with the financial covenants ofthe bond. Management has been in contact USDA to keep them informed on thesituation and has put plans into place to improve the financial position of the District.
The management agent will repay the funds on behalf of the related party housing project until that property has funds available, pending HUD approval.
The management agent will repay the funds on behalf of the related party housing project until that property has funds available, pending HUD approval.
Management agrees and is working to submit a RAD for PRAC application that would include this property and two other properties.
Management agrees and is working to submit a RAD for PRAC application that would include this property and two other properties.
Name of Contact Person – Matt Flett, Chief Financial Officer Corrective Action Plan The District will immediately re-implement monthly personnel activity reports for employees with multiple funding sources and semi-annual certifications for staff 100% funded by a federal grant. Grant program manager...
Name of Contact Person – Matt Flett, Chief Financial Officer Corrective Action Plan The District will immediately re-implement monthly personnel activity reports for employees with multiple funding sources and semi-annual certifications for staff 100% funded by a federal grant. Grant program managers, building administrators, and federally funded staff will receive training to ensure compliance with 2 C.F.R. §200.430. Proposed Completion Date: February 2026
The Non-Profit Affiliate has secured a pre-development loan to reimburse the Authority in FY2026. Additionally, the COCC reimbursed over 50% of the amount due at 06/30/2025 to the Public Housing Programs in July 2025. The remaining funds are being paid down quarterly and will be paid off by end of F...
The Non-Profit Affiliate has secured a pre-development loan to reimburse the Authority in FY2026. Additionally, the COCC reimbursed over 50% of the amount due at 06/30/2025 to the Public Housing Programs in July 2025. The remaining funds are being paid down quarterly and will be paid off by end of FY2026.
FINDING 2025-001 Finding Subject: Annual Report Card, High School Graduation Rate – Special Test and Provisions Contact Person Responsible for Corrective Action: Marilyn Hampton, Supervisor of Student Services Contact Phone Number and Email Address: (219) 933-2461, ext.1048 mehampton@hammond.k12.in....
FINDING 2025-001 Finding Subject: Annual Report Card, High School Graduation Rate – Special Test and Provisions Contact Person Responsible for Corrective Action: Marilyn Hampton, Supervisor of Student Services Contact Phone Number and Email Address: (219) 933-2461, ext.1048 mehampton@hammond.k12.in.us Views of Responsible Officials: We concur with the finding and will implement a corrective action plan. Description of Corrective Action Plan: To ensure compliance with the requirements related to the grant agreement and the Special Test and Provisions Annual Report Card, High School Graduation rate compliance, the School City of Hammond will put into place an effective internal control system. The School City of Hammond will maintain an effective control system for withdrawals from each of the schools within the school system. At the time of withdrawal, a withdrawal form, along with a verified ID will be copied by the school’s registrar or designee. This withdrawal form must include the signatures of a parent and principal. This is the first step in the monitoring process. This system for withdrawals will also include placing a copy of the withdrawal form in the student information system (PowerSchool Attachments). The documentation that needs to be attached to the withdrawal form should include documents that show a Records Request, proof that the student withdrew to attend another school or educational program that results in the awarding of a high school diploma, has immigrated to another country, or is deceased. Upon completion of the withdrawal at the school, a copy of the documentation will be kept at the school, and the original documentation will be placed into the cumulative record. The school will forward a digital copy to Student Services. Upon receipt of the digital copy at Student Services, the administrator will review the file and will sign off to indicate that the record has been reviewed and is complete. To ensure this process is implemented with fidelity, training will take place on a yearly basis with administrators and office staff on the procedures that need to be followed during the withdrawal process. Anticipated Completion Date: 01/31/2026
Recommendation: We recommend that management develop a plan to entice the youth workers to join the program so that they can meet the program compliance requirement. Management Response: Management agrees with the finding. See management’s attached corrective action plan.
Recommendation: We recommend that management develop a plan to entice the youth workers to join the program so that they can meet the program compliance requirement. Management Response: Management agrees with the finding. See management’s attached corrective action plan.
Highway Planning and Construction - Assistance Listing No. 20.205 Recommendation: We recommend that the City evaluate its procedures and implement an additional control to ensure verifications checks are occurring prior to entering into contracts with a vendor. Explanation of disagreement with audit...
Highway Planning and Construction - Assistance Listing No. 20.205 Recommendation: We recommend that the City evaluate its procedures and implement an additional control to ensure verifications checks are occurring prior to entering into contracts with a vendor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With the recent filling of open positions and the execution of contracts with engineering firms, additional controls have been implemented to strengthen project review processes. Specifically, the hiring of a City Administrator and an Economic Development Director will enhance controls over new established process. Name(s) of the contact person(s) responsible for corrective action: Kim Barfield Planned completion date for corrective action plan: 12/29/25
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