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Corrective Action Plans

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Finding 2210 (2023-002)
Significant Deficiency 2023
Bethany Fellowship, Inc.
CO
Student Financial Aid Reporting Significant Deficiency
Incorrect and Untimely Return of Title IV (R2T4) Calculations Planned Corrective Action: The academics and financial aid office will work in conjunction to run a zero-credit earned report at the end of each term and determine if there are any unidentified unofficial withdrawals that must be process...
Incorrect and Untimely Return of Title IV (R2T4) Calculations Planned Corrective Action: The academics and financial aid office will work in conjunction to run a zero-credit earned report at the end of each term and determine if there are any unidentified unofficial withdrawals that must be processed. Throughout the semester the academics department is logging attendance daily to ensure students do not fail for non-attendance and are not missing more than five without proper notice. For students in online courses, professors will check in on student engagement every two days, and the academic administrative team will do a check once a week to identify any students who may be an unofficial withdrawal. For the calendar for R2T4’s the Financial Aid office keeps an excel sheet with the term dates and breaks for the year and will manually check that the dates/percentages align with the calculations on the COD R2T4 calculator. The first couple of students processed will be calculated manually with the information in the excel sheet to ensure it aligns with the calculation completed on COD. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director and Tiffany Garrison, Interim Registrar Anticipated Date of Completion: 10/27/23
View Audit 3792
Arlington Baptist University
CO
Matching / Level of Effort / Earmarking
Right to Cancel Notifications Planned Corrective Action: New student information system (Campus Café) provides an automated email to students that once funds are disbursed they are notified. I will edit the email to include the information about the Right to Cancel including instructions. Person ...
Right to Cancel Notifications Planned Corrective Action: New student information system (Campus Café) provides an automated email to students that once funds are disbursed they are notified. I will edit the email to include the information about the Right to Cancel including instructions. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: 01/06/2024, before the spring disbursement.
View Audit 3747
Finding 2176 (2023-002)
Significant Deficiency 2023
Arlington Baptist University
CO
Student Financial Aid Matching / Level of Effort / Earmarking Significant Deficiency
Return of Title IV (R2T4) Calculations Planned Corrective Action: Set the calendar to match academic calendar and set up for awarding in COD. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.
Return of Title IV (R2T4) Calculations Planned Corrective Action: Set the calendar to match academic calendar and set up for awarding in COD. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.
View Audit 3747
Finding 2175 (2023-001)
Material Weakness 2023
Arlington Baptist University
CO
Reporting Student Financial Aid Eligibility
Enrollment Reporting to NSLDS Planned Corrective Action: Enroll in The National Clearing house to make reporting more automated and accurate. Set calendar reminder to send reports on a monthly schedule to make sure we report timely and accurately. Person Responsible for Corrective Action Plan: St...
Enrollment Reporting to NSLDS Planned Corrective Action: Enroll in The National Clearing house to make reporting more automated and accurate. Set calendar reminder to send reports on a monthly schedule to make sure we report timely and accurately. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.
View Audit 3747
Finding 2130 (2023-002)
Material Weakness 2023
Streator Esd No. 44
IL
Reporting Matching / Level of Effort / Earmarking § 200.302
Management is currently confident with the abilities of the accounting staff to prepare interim financial statements. The District has also accepted the additional risk associated with the auditor drafting year-end financial statements including the notes to the financial statements. Management wi...
Management is currently confident with the abilities of the accounting staff to prepare interim financial statements. The District has also accepted the additional risk associated with the auditor drafting year-end financial statements including the notes to the financial statements. Management will review, approve, and take responsibility for the financial statements.
View Audit 3688
Dallas Christian College
TX
Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking
Common Origination and Disbursement (COD) Reporting Planned Corrective Action: We’ve created a new activity in Anthology SIS labeled “FA – Return to Title IV” to be assigned to both FA staff and Student Accounts staff when returns are needed. These activities will include detailed notes as to what r...
Common Origination and Disbursement (COD) Reporting Planned Corrective Action: We’ve created a new activity in Anthology SIS labeled “FA – Return to Title IV” to be assigned to both FA staff and Student Accounts staff when returns are needed. These activities will include detailed notes as to what returns need to be applied to posted funds on the student’s ledger. This will ensure that we apply returns as required and that the returns applied also match the applied returns in COD. FA Solutions and DCC are aligned on better communications for returns that need to be applied to ensure accuracy going forward. Person Responsible for Corrective Action Plan: Jean-Claude St Juste, Financial Aid Director, Student Accounts staff, and FA Solutions staff. Anticipated Date of Completion: Immediately
View Audit 3665
Dallas Christian College
TX
Reporting Student Financial Aid Eligibility
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Incorrect enrollment reporting was found for one student. Currently, the Registrar’s Office, in coordination with the National Student Clearinghouse, reports enrollment to NSLDS. The program for th...
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Incorrect enrollment reporting was found for one student. Currently, the Registrar’s Office, in coordination with the National Student Clearinghouse, reports enrollment to NSLDS. The program for that one student was shown incorrectly in the system for a period during the audit. When checked later, still during the audit, the program was shown correctly without any action by personnel of the college. We are unsure of the cause of this inconsistency in that instance. The Financial Aid Office will start conducting weekly spot checks directly in NSLDS to help catch enrollment that may have been reported incorrectly. The first spot check is expected to be completed the week of November 13-17. Person Responsible for Corrective Action Plan: Jean-Claude St Juste, Financial Aid Director Anticipated Date of Completion: Immediately
View Audit 3665
Philadelphia College of Osteopathic Medicine Foundation
PA
Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking
Name of Responsible Individual: Samuel Matheny, Chief Student Services Officer, Offices of Financial Aid and Registrar Corrective Action: In fiscal year 2023 (FY23), the return of federal funds calculation and process was automated in the Banner student information system; therefore, reducing the po...
Name of Responsible Individual: Samuel Matheny, Chief Student Services Officer, Offices of Financial Aid and Registrar Corrective Action: In fiscal year 2023 (FY23), the return of federal funds calculation and process was automated in the Banner student information system; therefore, reducing the possibility of an incorrect calculation. Furthermore, a financial aid staff member reviewed the return of federal funds calculations twice during the fiscal year to ensure accuracy. However, it was determined that two of the students selected in the FY23 audit sample had incorrect academic dates used in their calculation. As a graduate/professional school, PCOM has several academic calendars rather than one institutional calendar. The need for multiple academic calendars is due to the variations in the start and end times of our students completing offsite clinical rotations. For fiscal year 2024 (FY24), PCOM will be implementing the following additional controls to ensure the correct academic calendar is used in the return of title 4 calculations: 1. Academic calendar dates will be added to the report used to review students who have withdrawn from their coursework. 2. The report will be run after the end of every term (4 times a year) and it will go through an initial review by one staff member and then a final review by another staff member. Anticipated Completion Date: September 1, 2023
View Audit 3573
Finding 2032 (2023-002)
Significant Deficiency 2023
Catholic Charities of the Diocese of Palm Beach County, Inc.
FL
Questioned Costs Allowable Costs / Cost Principles Cash Management
2023-002 Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreemen...
2023-002 Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A second staff person has completed the Department of Justice Grants Financial Management Training and is now qualified to work on the federal grants. This will allow the agency to have someone other than that the person creating the reimbursement material to request the reimbursement. This adds an additional layer of control over the amount requested for reimbursement. Name(s) of the contact person(s) responsible for corrective action: Peter Hermann Planned completion date for corrective action plan: November 6, 2023
View Audit 3565 Questioned Costs: $1
Finding 2025 (2023-002)
Significant Deficiency 2023
South Heartland District Health Department
NE
Matching / Level of Effort / Earmarking Subrecipient Monitoring
Program: AL 93.069 – Public Health Emergency Preparedness – Matching Corrective Action Planned: SHDHD monitors matching fund levels for Federal subawards on a quarterly basis to determine whether the match amount is on track toward meeting the percentage required in each grant agreement. Regarding t...
Program: AL 93.069 – Public Health Emergency Preparedness – Matching Corrective Action Planned: SHDHD monitors matching fund levels for Federal subawards on a quarterly basis to determine whether the match amount is on track toward meeting the percentage required in each grant agreement. Regarding the PHEP award, in particular, the Department will ensure that the new Emergency Response Coordinator (hired in the middle of the grant period last year) is aware of the match requirements. SHDHD will also ensure that no Federal funds are used to pay for matching funds required in Federal subawards. The Department was not aware that this was not allowable. Anticipated Completion Date: June 30, 2024 Responsible Party: Kelly Derby, Erik Meyer, Brooke Wolfe
View Audit 3537
Finding 2019 (2023-001)
Significant Deficiency 2023
University of San Diego
CA
Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking
October 24, 2023 Corrective Action Plan for University of San Diego Audit finding 2023-001 FINDING 2023-001 – Special Tests and Provisions – Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance Criteria –34 CFR section 685.300(b)(5): On a monthly ...
October 24, 2023 Corrective Action Plan for University of San Diego Audit finding 2023-001 FINDING 2023-001 – Special Tests and Provisions – Borrower Data Transmission and Reconciliation: Significant Deficiency in Internal Control Over Compliance Criteria –34 CFR section 685.300(b)(5): On a monthly basis, the University of San Diego must reconcile institutional records with Direct Loan funds received from the Secretary and Direct Loan disbursement records submitted to and accepted by the Secretary. Condition/Context – The University of San Diego operates a law school and an undergraduate and graduate school. A sample of 6 direct loan reconciliations were selected from the population of all reconciliations performed by the University, under both schools during the year ended June 30, 2023. We obtained the supporting schedules used to reconcile the disbursed direct loan funds to the federal government’s records. The University did not complete reconciliations of its direct loan program disbursements for the law school between December 2022 and June 2023. Cause – There was turnover in the position responsible for reconciling this data, and the responsibility did not transfer to another individual, and as a result, the reconciliations were not completed. Effect – There is a chance that the University of San Diego’s records may not match the federal government’s records of direct loan disbursement. Recommendation – The auditors recommend the University of San Diego revise the existing policies and procedures to ensure when a change in personnel occurs, responsibilities appropriately transfer to a new individual. Corrective action plan – Management concurs with this finding. This exception was due to the monthly reconciliation not being part of the established policies and procedures for the Law School Financial Aid Office. As a result, during staff turnover the interim staff were unaware of the responsibilities and requirements for the monthly reconciliation. Management updated the direct lending servicing system reconciliation procedures for the Law School to clearly delineate the responsible parties. Management believes these enhancements will be sufficient to prevent future errors. Anticipated completion date: October 2023 Persons responsible: Mike Chavez, Director of JD Admissions, Financial Aid & Diversity Initiatives
View Audit 3531
Finding 2005 (2023-001)
Significant Deficiency 2023
Bellefaire Jewish Children's Bureau
OH
Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.305
The Agency is updating its process to calculate the indirect costs in accordance with the revised notice of award (NOA) dated March 10, 2023. Additionally, the Agency will provide further training to all individuals involved in the financial management of federal awards. On a monthly basis, the ca...
The Agency is updating its process to calculate the indirect costs in accordance with the revised notice of award (NOA) dated March 10, 2023. Additionally, the Agency will provide further training to all individuals involved in the financial management of federal awards. On a monthly basis, the calculation of indirect costs eligible for reimbursement under this award will be compared to the indirect costs allowed for in the NOA. This calculation will be secondarily reviewed by an individual having financial oversight on federal awards to ensure that any reimbursement request is computed in accordance with the NOA. The reimbursement request will then be submitted only after this verification has been completed. Contact person responsible for corrective action: Scott Moore, Chief Financial Officer Anticipated completion date: December 31, 2023
View Audit 3451
Finding 1843 (2023-003)
Material Weakness 2023
Black River Public School
MI
Questioned Costs Special Tests & Provisions Material Weakness
2023-003 - Wage Rate Requirements Auditor Description of Condition and Effect. The School did not include the federal wage rate requirements in their contracts and did not obtain the required certified payrolls for its contractors subject to the federal rate requirements. As a result of this conditi...
2023-003 - Wage Rate Requirements Auditor Description of Condition and Effect. The School did not include the federal wage rate requirements in their contracts and did not obtain the required certified payrolls for its contractors subject to the federal rate requirements. As a result of this condition, the School did not follow federal requirements to include the prevailing wage rate provision in its contract. Auditor Recommendation. We recommend that the School 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. Going forward, if Black River participates in a federally funded project, we will make sure that prevailing wage requirements will be included in the contract. Responsible Person. John Zoellner - Director of Business. Anticipated corrective action June 30, 2024
View Audit 3208 Questioned Costs: $1
Anderson University and Subsidiaries
IN
Questioned Costs Student Financial Aid Allowable Costs / Cost Principles
Need Analysis Planned Corrective Action: PowerFAIDS, a new financial aid processing software, was adopted by the Anderson University Office of Financial Aid this year. It was discovered that PowerFAIDS does not automatically correct the student’s need-based aid when additional aid is added manually ...
Need Analysis Planned Corrective Action: PowerFAIDS, a new financial aid processing software, was adopted by the Anderson University Office of Financial Aid this year. It was discovered that PowerFAIDS does not automatically correct the student’s need-based aid when additional aid is added manually after a student has been packaged. The assumption of the Financial Aid Office was that this was automatically adjusting as it had done in the previous system used. The Senior Associate Director reached out to PowerFAIDS to get an understanding of when manual calculations need to be done to a student’s need-based aid. In light of this new information, the Financial Aid Office will adjust their practice going forward. When additional aid is awarded going forward, need based aid will be manually adjusted so that students are not over awarded in need-based aid. Person Responsible for Corrective Action Plan: David J. Sarah, Director Anticipated Date of Completion: Students who were over awarded in Federal Direct Subsidized Loans were corrected on COD effective 08/17/2023.
View Audit 3116 Questioned Costs: $1
Finding 1788 (2023-001)
Material Weakness 2023
Anderson University and Subsidiaries
IN
Questioned Costs Student Financial Aid Material Weakness
Untimely and Inaccurate Return of Title IV Funds Planned Corrective Action: FA Solutions (FAS), a third-party vendor, was contracted to assist with compliance and other processing responsibilities that included the processing of all R2T4s for Anderson University. While the staff of the Office of Fin...
Untimely and Inaccurate Return of Title IV Funds Planned Corrective Action: FA Solutions (FAS), a third-party vendor, was contracted to assist with compliance and other processing responsibilities that included the processing of all R2T4s for Anderson University. While the staff of the Office of Financial Aid and Scholarships supplied documentation to FAS in a timely manner, FAS processed R2T4 late and, in some cases, inaccurately. When this was discovered by the Office of Financial Aid and Scholarships, all R2T4 and processing responsibilities were brought back under the in-office staff at AU in order to process Return of Title IV funds accurately and in compliance. Anderson University has enrolled our Senior Counselor in a 6-week R2T4 course with the National Association of Student Financial Aid Administrators (NASFAA) where she will pursue credentialing in Return of Title IV Funds with NASFAA as well as R2T4 Specialist designation. Additionally, policies for students who stop attending, and for whom the last day of attendance can not be determined, will be reviewed and revised for clarity and better communication with the Office of Financial Aid and Scholarships. Person Responsible for Corrective Action Plan: David J. Sarah, Director Anticipated Date of Completion: The return of all processing of financial aid was brought back to AU effective 06/20/2023. The R2T4 course taken by our Senior Counselor will be completed 11/06/2023. Final R2T4 adjustments completed 10/20/2023.
View Audit 3116 Questioned Costs: $1
Guilford County
NC
Eligibility Matching / Level of Effort / Earmarking
2023-001 Name of Contact Person: Sharon Barlow Corrective Action: Training and monitoring will place an increased emphasis on documentation. Proposed Completion Date: Tra...
2023-001 Name of Contact Person: Sharon Barlow Corrective Action: Training and monitoring will place an increased emphasis on documentation. Proposed Completion Date: Training and monitoring are ongoing.
View Audit 3049
Finding 1732 (2023-001)
Significant Deficiency 2023
Concordia University, Nebraska
NE
Questioned Costs Student Financial Aid Significant Deficiency
U.S. Department of Education Concordia University, Nebraska respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are nu...
U.S. Department of Education Concordia University, Nebraska respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 01, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT There were no financial statement findings in the current year. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Name(s) of the contact person(s) responsible for corrective action: David L Kumm, Executive VP CFO/COO Planned completion date for corrective action plan: 7/1/2022
View Audit 3010 Questioned Costs: $1
Finding 1731 (2023-001)
Significant Deficiency 2023
St. Mary's University of San Antonio, Texas
TX
Matching / Level of Effort / Earmarking Special Tests & Provisions Student Financial Aid § 200.303
To correct this error and ensure all disbursement notifications are sent, the following corrective actions have been implemented. 1. Modified the FA_RZLNDSB_Loan_Process_to_BDM script (weekly job that emails students with loan disbursements within the last 7 days) by removing the logic that used aid...
To correct this error and ensure all disbursement notifications are sent, the following corrective actions have been implemented. 1. Modified the FA_RZLNDSB_Loan_Process_to_BDM script (weekly job that emails students with loan disbursements within the last 7 days) by removing the logic that used aid year to identify which year to use when pulling disbursement records and instead allows all disbursed loans that occurred within the last 7 days, regardless of aid year, to be pulled for notification. 2 Created a new FA_RZLNDSB_Loan_Process_to_BDM_Weekly Error script, that identifies students that do not have an email entry on RUAMAIL form (GURMAIL table) for disbursed loans. This script then generates the email and PDF to be sent to the student.
View Audit 3005
Finding 1728 (2023-002)
Significant Deficiency 2023
St. Mary's University of San Antonio, Texas
TX
Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303
To eliminate student data input errors, the following corrective actions will be implemented: 1. For TRiO SSS program, the University will automate student data information migration from the existing ERP Banner system into the program database.  This database automation/migration will minimize stud...
To eliminate student data input errors, the following corrective actions will be implemented: 1. For TRiO SSS program, the University will automate student data information migration from the existing ERP Banner system into the program database.  This database automation/migration will minimize student data entry points that are currently keyed in manually. Each of the TRIO programs will perform additional reviews on the student data.  The following procedures will be implemented: For all data entered manually into a program’s database, the data will be reviewed by the person who keyed in the data or a separate individual based on staffing availability. The individual will review the data input for accuracy and sign off indicating the data has been reviewed and is correct. Every month each program’s PD will pull a random sample of 25 student records for error verification.  If a single data error is found in a program, then the random sample will be expanded by another 25 student records.  If an additional data error is found, all the remaining new student records entered that month will be verified by the PD. All errors identified will be corrected before submission of the APR. For all programs, error message reports and subsequent data revisions will be printed, saved, and reviewed by the PDs to verify accuracy of corrections.
View Audit 3005
East Texas Baptist University
TX
Allowable Costs / Cost Principles Eligibility Matching / Level of Effort / Earmarking
Need Analysis Planned Corrective Action: ETBU financial aid staff have used a Jenzabar PX product for over 20 years. Within that product, there is no built-in compliance to assist with awarding and managing Federal Direct Loan awarding amounts based on need. The initial Federal Direct Loans were aw...
Need Analysis Planned Corrective Action: ETBU financial aid staff have used a Jenzabar PX product for over 20 years. Within that product, there is no built-in compliance to assist with awarding and managing Federal Direct Loan awarding amounts based on need. The initial Federal Direct Loans were awarded correctly based on student need eligibility. However, when scholarships were added/removed or aid was adjusted based on enrollment status after origination, manual adjustments to loans are required. As a result of previous finding, ETBU implemented processes where Direct Subsidized Loans were over awarded when scholarships were added after initial packaging and eliminated all finding related to Need Analysis in 2022-2023. However, the quality assurance checks were not written to check for reduction of scholarships that might result in an under award of Direct Subsidized Loans. ETBU has a log file to document that the student elected to reduce their subsidized loan which was determined to be a finding. After further review of regulations, ETBU financial aid was only honoring the student request. ETBU financial aid office added this quality assurance check to their procedures and has conducted a 100% check for all Federal Direct Student loans for the 2022- 23 award year for over awards as well as under awarding of all Direct Loans. ETBU financial aid has implemented a new administrative software, Jenzabar Financial Aid (JFA) for the 2023-24 financial aid year. JFA has built in Federal Direct Loan packaging that checks need at the time of awarding, as well as, evaluating need when awards are changed. Additionally, quality assurance processes have been written in the new software to double check Federal Direct Loan award amounts after any funding movement on student accounts. These processes are completed before any loan disbursements to assure that compliance is maintained. Person Responsible for Corrective Action Plan: Linda Slawson, Director Financial Aid Anticipated Date of Completion: Completed
View Audit 2989
Missouri Housing Development Commission
MO
Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.400 § 200.401
Finding 2023-003 – Allowable Costs and Activities, Eligibility – Compliance Federal Award. No. 21.026 Homeowner Assistance Fund – COVID 19 Corrective Action Plan: The Commission was made aware of the sophisticated fraudulent entity through its contacts with the National Council of State Housing Agen...
Finding 2023-003 – Allowable Costs and Activities, Eligibility – Compliance Federal Award. No. 21.026 Homeowner Assistance Fund – COVID 19 Corrective Action Plan: The Commission was made aware of the sophisticated fraudulent entity through its contacts with the National Council of State Housing Agencies (NCSHA). Staff remains active in those groups, participating in weekly and monthly calls and will adopt further preventative measures that have been shown to be effective in other states. Staff has implemented a more rigorous servicer onboarding process, whereby questionable items or documentation deemed to be suspicious or potentially altered will be presented to the program director, finance staff, compliance staff, or other internal staff for further investigation. Staff does not anticipate further issues with falsified information with the enhanced onboarding procedures implemented. In addition, balances owed are verified by loan servicers, and funds are paid directly to the servicer and never to individual homeowners. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2023 and completed its investigation of the identified case. Contact Person: Steve Whitson, Director of Community Programs
View Audit 2908 Questioned Costs: $1
Finding 1672 (2023-002)
Material Weakness 2023
Missouri Housing Development Commission
MO
Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.400 § 200.401
Finding 2023-002 – Allowable Costs and Activities, Eligibility – Compliance and Control Finding Federal Award No. 21.023 Emergency Rental Assistance Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission...
Finding 2023-002 – Allowable Costs and Activities, Eligibility – Compliance and Control Finding Federal Award No. 21.023 Emergency Rental Assistance Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. Past and ongoing measures implemented to ensure eligibility of all funds disbursed include: the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that were responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021, the Commission hired an Internal Compliance Manager and created an Internal Compliance Department who has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity was expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as “mass denial metrics” and tiered level reviews were implemented into weekly application processing. Commission staff set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative or other review measures demonstrated to be effective in other states. As program funds for direct rental and utility assistance have been expended and direct assistance applications no longer accepted, additional internal metrics and compliance review processes are being developed to apply a consistent process for examining any outstanding questioned costs and to make a final determination regarding the eligibility of disbursed funds. Completion Date: The Commission implemented additional compliance review procedures during fiscal years 2021 and 2022 and expects to conclude its investigation of the fiscal year identified cases during calendar year 2024. Contact Person: Steve Whitson, Director of Community Programs
View Audit 2908 Questioned Costs: $1
Finding 1670 (2023-001)
Material Weakness 2023
Missouri Housing Development Commission
MO
Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.400 § 200.401
Finding 2023-001 – Allowable Costs and Activities – Compliance and Control Finding Federal Award No. 14.231 Emergency Solutions Grant Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the ...
Finding 2023-001 – Allowable Costs and Activities – Compliance and Control Finding Federal Award No. 14.231 Emergency Solutions Grant Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The use of program funds for direct rental assistance under this program was concluded and the final disbursements made in early May 2021. Past and ongoing measures implemented to ensure eligibility of all funds disbursed include: The Commission hiring an Internal Compliance Manager and establishing an internal compliance department in May 2021 who engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. As program funds for direct rental assistance have been expended, additional internal metrics and compliance review processes are being developed to apply a consistent process for examining any outstanding questioned costs and to make a final determination regarding the eligibility of disbursed funds. Completion Date: The Commission implemented additional compliance review procedures during fiscal years 2021 and 2022, reviewed applications to identify potentially fraudulent applications during fiscal years 2022 and 2023 and expects to conclude its investigation of identified cases during fiscal year 2024. Contact Person: Steve Whitson, Director of Community Programs
View Audit 2908 Questioned Costs: $1
Saint Xavier University
IL
Questioned Costs Special Tests & Provisions Student Financial Aid
2023-001: Improper Return of Title IV Financial Aid - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264 - Grant Period - Year Ended June 30, 2023 Condition Found: During our Return of Title IV Fund testing, we noted that the University did not...
2023-001: Improper Return of Title IV Financial Aid - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.038, 84.063, 84.268, 84.379, 93.264 - Grant Period - Year Ended June 30, 2023 Condition Found: During our Return of Title IV Fund testing, we noted that the University did not calculate properly or return Title IV Student Financial Aid in the required time frame for two out of twenty-five students we tested. We consider the untimely returns and incorrect calculations of the Return of Title IV to be an instance of noncompliance to the Special Tests and Provisions Compliance Requirement. This is also a repeat finding reported in Section IV Prior Year Financial Statement and Federal Award findings as 2022-001. Corrective Action Plan Action has already been completed. In both cases, the calculation was complete timely, but there were errors in the calculation. When the errors were identified, both calculations were purged and recalculated and the correct funds were returned. Manager currently reviews all refund calculations to ensure accurate calculations and will continue that practice to ensure compliance. Responsible Person for Corrective Action Plan Susan Swisher, Executive Director Office of Financial Aid. Implementation Date of Corrective Action Plan
View Audit 2826 Questioned Costs: $1
North Greenville University
SC
Allowable Costs / Cost Principles Eligibility Matching / Level of Effort / Earmarking
Need Analysis Planned Corrective Action: The financial aid staff has reporting available within PowerFAIDS to monitor and check for oversights related to need analysis. The team will review the reports to ensure that they are set up properly to identify such issues created by human error, as well a...
Need Analysis Planned Corrective Action: The financial aid staff has reporting available within PowerFAIDS to monitor and check for oversights related to need analysis. The team will review the reports to ensure that they are set up properly to identify such issues created by human error, as well as ensuring that these reports are being monitored more regularly. The team is also investigating what additional information can be added to the PowerFAIDS student financial aid portal to help students better understand the benefits of accepting a subsidized loan over an unsubsidized loan. Person Responsible for Corrective Action Plan: Cindi Patterson, Director for Financial Aid Anticipated Date of Completion: December 2023
View Audit 2823
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