Corrective Action Plans

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Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported t...
Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported to Common Origination and Disbursement (COD). Auditors' Recommendation: The University should review their policies and procedures to ensure accurate reporting to COD. School Response: The University agrees with this finding and has initiated corrective action. Corrective Action Plan: Title IV disbursements must be posted to student accounts within 15 days of the funds drawdown. Also, the disbursement date per COD must match the disbursement date on the student account. There was one instance in which the Disbursement date for a Pell Grant was 10/10/2022 per COD and 10/19/2022 on the student's account. One instance had a disbursement date at COD as 2/16/2023 and at 2/15/2023 on the student's account. The third instance had a disbursement date of 1/25/23 at COD and 1/26/23 on the student's account. Each of these disbursements were posted in the old Student Information System (SIS), Anthology. The posting process that the school used under the previous system relied primarily on manual checks by employees in various departments in which reports could be sent to COD in which the posting dates did not match the COD dates. In order to avoid this finding in the future, the University has sought out and implemented a new Student Information System (SIS), Colleague, beginning with the 2023-24 award year. The school has also contracted with a third-party servicer, Financial Aid Services (FAS}, to assist with packaging students and completing the disbursement process. To disburse funds, the Director of Financial Aid Quality and Compliance or the representative from FAS runs a report in Colleague which pulls scheduled and approved financial aid disbursements for students who have met the enrollment criteria to receive those disbursements. The report goes to the student accounts office where the financial aid is posted to the student ledgers. Then it is transmitted to COD with the posted dates so that the dates reported to COD match the dates in the SIS. If there are any errors in the transmission, the Director of Financial Aid Quality and Compliance or the representative from FAS will review the rejected disbursements and make corrections to get them processed as quickly as possible. The accounting office submits the drawdown request to G-5 for the amount of the approved and posted financial aid. The new process in which the disbursement amounts and dates transmitted to COD match the disbursement amounts and dates posted to the students' ledgers is expected to ensure compliance in the future. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Quality and Compliance, Rachal Wortham Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on new disbursement process completed August 2023. • First disbursements approved using the new SIS done by Director of Financial Aid Quality and Compliance August 2023. • Review of disbursement process with FAS October 2023. • Follow up with Colleague team to review the process and work out any flaws February 2024.
Condition: There were no monthly Title IV reconciliations performed. Criteria: Per SFA requirements, the College is required to reconcile the COD data files with the College’s financial records. Cause: Turnover in the staff and Director positions of the College. The new employees were not aware o...
Condition: There were no monthly Title IV reconciliations performed. Criteria: Per SFA requirements, the College is required to reconcile the COD data files with the College’s financial records. Cause: Turnover in the staff and Director positions of the College. The new employees were not aware of this requirement. Effect: Noncompliance with SFA requirements. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. Recommendation: We recommend that the direct loans are reconciled at least monthly between the COD and the College’s general ledger. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved have received training and been made aware of requirements. Monthly reconciliations will be performed immediately.
Condition: We examined a sample of Title IV aid recipients to verify that information reported on the Enrollment Reporting roster file sent to the National Student Loan Data System (NSLDS) matched the student's academic files and found instances where students received Title IV aid during a semester...
Condition: We examined a sample of Title IV aid recipients to verify that information reported on the Enrollment Reporting roster file sent to the National Student Loan Data System (NSLDS) matched the student's academic files and found instances where students received Title IV aid during a semester but the status of withdrawn or graduate were not reported correctly or timely on the NSLDS Enrollment Reporting roster files sent during that semester. Criteria: Per the NSLDS Enrollment Reporting Guide, a school should report all students that NSLDS includes in its request to the school on a roster file. This includes timely and accurate reporting of the status of the student of withdrawn or graduate. Cause: The status of the students were not timely and accurately reported to NSLDS. Effect: Students could potentially not be placed in grace or repayment status when they should be. Perspective: There has been high turnover in the SFA department, including a time where there was not a Director in place. They have had interim Director who also left in December 2023. A new Director has been hired in January 2024 and has begun working on issues. Recommendation: We recommend that personnel in charge of enrollment reporting be diligent in reviewing the roster file to ensure that all appropriate students are shown and attendance changes are reported in a timely and accurate manner. Views of Responsible Officials and Planned Corrective Actions: Dodge City Community College staff involved in enrollment reporting to the NSLDS have reviewed the NSLDS Reporting Manual to better understand and accurately report the student's enrollment status. There has been high turnover in the SFA department, including a time where there was not a Director in place. The new Director came on in the fall of 2022 and then left in December 2023. The College is still working on fully implementing new procedures and catching up submissions.
Finding 372299 (2023-002)
Significant Deficiency 2023
Finding No. 2023-002 Corrective Action Plan: The University concurs with the finding. The Financial Aid office is in the process of tightening its policies and procedures to identify all students subject to the required exit counseling, with the goal of delivering said counseling within the prescrib...
Finding No. 2023-002 Corrective Action Plan: The University concurs with the finding. The Financial Aid office is in the process of tightening its policies and procedures to identify all students subject to the required exit counseling, with the goal of delivering said counseling within the prescribed 30-day window. Responsible Official: John Sircy, Interim CFO Anticipated Completion Date: June 2024
FINDING No. 2023-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should improve monitoring of the payroll disbursement process to ensure the appropriate approved wages are paid. Action Taken: Additio...
FINDING No. 2023-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should improve monitoring of the payroll disbursement process to ensure the appropriate approved wages are paid. Action Taken: Additional payroll controls are being evaluated and implemented in 2024. This will include establishing procedures to ensure the completeness and accuracy of payroll and related oversight. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO
View Audit 293594 Questioned Costs: $1
Finding 372278 (2023-001)
Significant Deficiency 2023
Individuals Responsible for Corrective Action Plan Wanda Spradley, Director, Financial Aid Susan Kennon, Registrar Jennifer Sauer, AVP for Finance Corrective Action Plan: The finding is related to required enrollment information being reported to National Student Loan Data System by the registr...
Individuals Responsible for Corrective Action Plan Wanda Spradley, Director, Financial Aid Susan Kennon, Registrar Jennifer Sauer, AVP for Finance Corrective Action Plan: The finding is related to required enrollment information being reported to National Student Loan Data System by the registrar’s office. The errors noted in 2023-001, as well as 2022-001, were primarily related to a lack of internal systems, staff, and expertise in the reporting requirements. A new registrar was hired September 2023, and much work has been done to increase staffing and technology support for the office. The administration is working with the registrar’s office to implement controls to reduce errors and improve timeliness. However, reporting requirements are rigorous, and there will always be challenges. With new systems only recently put in place and the staffing issues continuing in FY23-24, this finding may be noted again next year. Anticipated Completion Date: June 30, 2024
Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Man...
Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the audit finding where some MPNs are missing. We are unable to correct the past but moving forward, the new ones are being retained. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: September 1, 2023
Housing Choice Vouchers - CFDA No. 14.871 - PIC Reporting Recommendation: The Authority should implement processes to ensure the HUD-50058's are submitted into the PIC system timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...
Housing Choice Vouchers - CFDA No. 14.871 - PIC Reporting Recommendation: The Authority should implement processes to ensure the HUD-50058's are submitted into the PIC system timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The HUD-50058 submissions are done daily but there are exceptions where we find that some 50058's submitted do not return as an error later we notice that are not showing in PIC and have to be resubmitted. This has been reported to our field office and the PIC Help Desk with no resolution. Name(s) of the contact person(s) responsible for corrective action: Maria Godwin Planned completion date for corrective action plan: Ongoing
Finding Number: 2023-002 Condition: Out of 60 allowability samples that were tested, one expenditure tested was determined to be incorrectly charged to this grant. Planned Corrective Action: The College of Cooperative Education and Professional Studies (CCPS) has instituted several reforms to prev...
Finding Number: 2023-002 Condition: Out of 60 allowability samples that were tested, one expenditure tested was determined to be incorrectly charged to this grant. Planned Corrective Action: The College of Cooperative Education and Professional Studies (CCPS) has instituted several reforms to prevent future instances of this nature. The Program Director is now required to review and sign-off on all transactions before they are charged to the project, to ensure all charges are appropriate. New staff have been assigned to the project to process transactions, and the CCPS business office is now meeting monthly to review project activity, discuss any questions, and address any concerns regarding financial activities. Additionally, the university is drafting a new policy to review and, if needed, provide additional administrative support for large, complex grant projects. This policy will require that grant proposals above a certain dollar threshold are reviewed by the Office of Research prior to submission to ensure proper resources will be available to manage the project if awarded. In cases where the Office of Research determines additional resources may be needed, they will be authorized to require additional support be included in the grant proposal, or else provide additional administrative help to the unit at the time of award. Contact person responsible for corrective action: CCPS: Jeremy Harvey, Jodi Sleyo, and Bailey Bartels. Office of Research: Patrick Clark Anticipated Completion Date: CCPS changes have been implemented as of 10/11/2023; policy changes to be completed by 6/30/2024.
View Audit 293505 Questioned Costs: $1
Finding #2023-001 -Limited Segregation of Duties (Prior Year Finding #2022-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected...
Finding #2023-001 -Limited Segregation of Duties (Prior Year Finding #2022-001) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the district's operations. Response: We agree with this finding and continue to work to achieve segregation of duties whenever cost effective. The cash disbursements process includes approval of purchase orders and matching of approved purchase orders with invoices. Review of account coding is perfo1med by the district accounting staff. The payroll disbursement process includes approval of timesheets and review of coding on an ongoing basis. The Board of Education reviews budget to actual information along with disbursement information monthly.
ACOE updated the new Time and Effort policy and offered agency-wide training.
ACOE updated the new Time and Effort policy and offered agency-wide training.
View Audit 293447 Questioned Costs: $1
Finding 2023‐002 Material weakness in internal controls over compliance for earmarking and material noncompliance for earmarking in the U.S. Refugee Admissions Program. Contact Person(s): Nicholas Lee, Chief Financial Officer Corrective action planned: The accounting team will work alongside the pro...
Finding 2023‐002 Material weakness in internal controls over compliance for earmarking and material noncompliance for earmarking in the U.S. Refugee Admissions Program. Contact Person(s): Nicholas Lee, Chief Financial Officer Corrective action planned: The accounting team will work alongside the program management to develop and maintain a client tracker. Monthly meetings will be established to review spend, and resolve any questions. The client tracker will be established for the entire FYE June 30, 2024, and completed by August 31, 2024. The meetings will be established prior to the FYE June 30, 2024. Anticipated completion date: August 31, 2024
Enrollment certifications will be sent to the National Student Clearninghouse on a monthly basis, no later than 10 days following the end of the month. The final degree file will be submitted no later than 30 days after the last day of class, with additional awards submitted individually. The Financ...
Enrollment certifications will be sent to the National Student Clearninghouse on a monthly basis, no later than 10 days following the end of the month. The final degree file will be submitted no later than 30 days after the last day of class, with additional awards submitted individually. The Financial Aid Director will review all NSLDS errors.
Doane has reviewed the finding and is researching ways to improve the process.
Doane has reviewed the finding and is researching ways to improve the process.
The Financial Aid team is conducting staff training regarding return to Title IV calculations and compliance led by the Financial Aid Director. This includes all return to Title IV calculations being reviewed by the Financial Aid Director before final submission.
The Financial Aid team is conducting staff training regarding return to Title IV calculations and compliance led by the Financial Aid Director. This includes all return to Title IV calculations being reviewed by the Financial Aid Director before final submission.
View Audit 293420 Questioned Costs: $1
Management is responsible for establishing a comprehensive information security policy to safeguard sensitive data. Personnel Responsible for Corrective Action: Tonya Mourning, Chief Financial Officer, and Mike Pepple, Student Financial Services Director. Anticipated Completion Date: Corrective act...
Management is responsible for establishing a comprehensive information security policy to safeguard sensitive data. Personnel Responsible for Corrective Action: Tonya Mourning, Chief Financial Officer, and Mike Pepple, Student Financial Services Director. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2024. Corrective Action Plan: Management will continue to implement the remaining compliance requirements into a comprehensive policy.
Federal Direct Loan and Pell disbursement dates per the University's billing system did not agree with the reported dates per the Common Origination Disbursement (COD) records. Additionally, Pell award amount did not agree between the students' file and COD records. Personnel Responsible for Correct...
Federal Direct Loan and Pell disbursement dates per the University's billing system did not agree with the reported dates per the Common Origination Disbursement (COD) records. Additionally, Pell award amount did not agree between the students' file and COD records. Personnel Responsible for Corrective Action: Tonya Mourning, Chief Financial Officer, and Mike Pepple, Student Financial Services Director. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2024. Corrective Action Plan: Pell and Direct Loan origination records and disbursement records are submitted to the Common Origination Disbursement (COD) either same business day, or next business day. Formal reconciliation process is now completed every month in order to verify disbursement dates and amounts in COD.
Finding 372099 (2023-001)
Significant Deficiency 2023
Enrollment information was not submitted accurately or within the required timeframe by the University. Personnel Responsible for Corrective Action: Tonya Mourning, Chief Financial Officer, and Mike Pepple, Student Financial Services Director. Anticipated Completion Date: Corrective action plan will...
Enrollment information was not submitted accurately or within the required timeframe by the University. Personnel Responsible for Corrective Action: Tonya Mourning, Chief Financial Officer, and Mike Pepple, Student Financial Services Director. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2024. Corrective Action Plan: Management has hired a new Student Financial Services Director and is aware of the federal regulations surrounding enrollment information that must be reported to the NSLDS. Given the complexity of the reporting, management has established additional policies and procedures to address the errors related to enrollment reporting to the NSLDS in a timely and accurate manner.
CORONAVIRUS STATE AND LOCAL RECOVERY FUNDS, ASSISTANCE LISTING 21.027 : INELIGIBLE COSTS / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATE "EXCEPT WHERE OTHERWISE AUTH...
CORONAVIRUS STATE AND LOCAL RECOVERY FUNDS, ASSISTANCE LISTING 21.027 : INELIGIBLE COSTS / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATE "EXCEPT WHERE OTHERWISE AUTHORIZED BY STATUTE, COSTS MUST MEET THE FOLLOWING CRITERIA IN ORDER TO BE ALLOWABLE UNDER FEDERAL AWARDS: (F) NOT BE INCLUDED AS A COST OR USED TO MEET COST SHARING OR MATCHING REQUIREMENTS OF ANY OTHER FEDERALLY-FINANCED PROGRAM IN EITHER THE CURRENT OR PRIOR PERIOD. / THE CITY OF EAST PRAIRIE RECEIVED ARPA FUNDS THROUGH MISSISSIPPI COUNTY, MISSOURI FOR THE REMOVAL OF ASBESTOS AND DEMOLITION OF A HAZARDOUS SCHOOL STRUCTURE IN ORDER TO FACILITATE THE CONSTRUCTION OF A PUBLIC HEALTH FACILITY IN AUGUST AND SEPTEMBER, 2022. IN DECEMBER OF THE SAME YEAR, THE CITY RECEIVED WAS AWARDED AND ARPA GRANT AND FUNDS THROUGH THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION FOR THE SAME PROJECT. THIS WAS A DUPLICATION OF ARPA FUNDS DUE TO THE CITY NOT BEING FULLY AWARE OF THE COST STANDARDS OF UNIFORM GUIDANCE AND A MISCOMMUNICATION REGARDING ELIGIBILITY OF COSTS. / THE CITY OF EAST PRAIRIE HAS CONTACTED MISSISSIPPI COUNTY AND WILL BE RECEIVING AUTHORIZATION FROM THE MISSISSIPPI COUNTY COMMISSION TO RE-ALLOCATE THOSE FUNDS FOR THE SAME PUBLIC HEALTH FACILITY PROJECT. WE ARE ALSO DEVELOPING A WRITTEN POLICY AND PROCEDURE MANUAL CONFORMING TO UNIFORM GUIDANCE.
View Audit 293337 Questioned Costs: $1
Enrollment Reporting Name of contact person responsible for Corrective Action Plan: Whitney Costner, Registrar Corrective Action Plan: We concur with the finding. The University is currently implementing additional controls and procedures to ensure that all student roster files are reviewed, updated...
Enrollment Reporting Name of contact person responsible for Corrective Action Plan: Whitney Costner, Registrar Corrective Action Plan: We concur with the finding. The University is currently implementing additional controls and procedures to ensure that all student roster files are reviewed, updated, and submitted in accordance with applicable compliance requirements. Anticipated Completion Date: January 2024
Finding Number: 2023-006 Condition: Of the 9 students selected for enrollment reporting testing, the Seminary did not properly update student enrollment Information for 1 student in a timely manner. Planned Corrective Action: For students who finish their degree in December, they are reported as "wi...
Finding Number: 2023-006 Condition: Of the 9 students selected for enrollment reporting testing, the Seminary did not properly update student enrollment Information for 1 student in a timely manner. Planned Corrective Action: For students who finish their degree in December, they are reported as "withdrawn" as there is no option to confer in December (institutional policy). The student status is updated to "graduated" and reported to Clearinghouse in May when students are conferred. Contact person responsible for corrective action: Vince McGlothin-Eller, Registrar Anticipated Completion Date: 05/31/2024
Finding Number: 2023-005 Condition: During our review of internal controls and testing procedures, it was noted that no reconciliations could be provided. In addition, the Seminary does not have a quality assurance system in place. Planned Corrective Action: Within 1-2 weeks of each month's end, the...
Finding Number: 2023-005 Condition: During our review of internal controls and testing procedures, it was noted that no reconciliations could be provided. In addition, the Seminary does not have a quality assurance system in place. Planned Corrective Action: Within 1-2 weeks of each month's end, the Financial Aid Director requests a report from COD (US Department of Education Common Origination & Disbursement) for Direct Loans disbursed that month. That report is retrieved through EDConnect and reviewed. Financial Aid Director generates a report from Jenzabar Financial Aid system of Direct Loans disbursed for that month. The Financial Aid Director also retrieves a report of Direct Loans applied to students' accounts for that month from Business Office Senior Accountant. These three reports are then compared and reconciled for each month. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: Beginning 10/1/2023 (after first month of disbursement)
Finding Number: 2023-004 Condition: The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the student's ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance Planned...
Finding Number: 2023-004 Condition: The Seminary did not maintain appropriate documentation to substantiate the allowable charges on the student's ledger account to identity whether credit balances were created and required additional documentation from the student to hold the credit balance Planned Corrective Action: Beginning with the Fall 2023 term, Title IV credit balances are no longer held past the 14 days with authorization from the student. The Financial Aid Director implemented a new policy where students cannot request that these funds are retained beyond 14 days. There is a shared list where the Business Office enters the date that the students’ credit balance was released to verify that process happens within 14 days. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: 09/20/2023 (first day of Fall disbursement)
Finding Number: 2023-002 Condition: Of the 19 students who received disbursements selected for testing, the Seminary did not notify any of the students or parents, as applicable, that received direct federal loans within the required 30 days. Planned Corrective Action: Directly after a students’ Dir...
Finding Number: 2023-002 Condition: Of the 19 students who received disbursements selected for testing, the Seminary did not notify any of the students or parents, as applicable, that received direct federal loans within the required 30 days. Planned Corrective Action: Directly after a students’ Direct Loan is disbursed, Financial Aid Director manually sends the loan disbursement notification email to the student (through the Jenzabar financial aid system), which specifies the amount that they borrowed for the term and the right to cancel the loan within 14 days by emailing the Financial Aid Office. This email is recorded in the Jenzabar Financial Aid system. The Financial Aid Director also created a spreadsheet to track Direct Loan disbursements and notifications each term. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: 09/20/2023 (first day of Fall disbursement)
Finding Number: 2023-007 Condition: The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP). Planned Corrective Action: Satisfactory academic progress is now being monitored more carefully. ...
Finding Number: 2023-007 Condition: The Seminary did not identify or provide the appropriate notification to a student that was not meeting the Seminary's policy on satisfactory academic progress (SAP). Planned Corrective Action: Satisfactory academic progress is now being monitored more carefully. The Satisfactory academic progress report is run out of the student financial aid system. The internally generated report is reviewed by the Registrar and Financial Aid Director to confirm that student satisfactory academic progress statuses are correct. Once the appropriate status is confirmed, the Financial Aid Director will document students who are not in compliance with the institution’s policy and provide notifications to each student through email. The emails are recorded in the students' Jenzabar financial aid account. Contact person responsible for corrective action: Ashley Schreiner, Director of Financial Aid Anticipated Completion Date: 06/01/2024
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