Corrective Action Plans

Finding 42786 (2022-003)

Significant Deficiency 2022

IL

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

The University will review processes to ensure that adequate internal control exists to mitigate risks related to collection of required verification documents are collected. 1) Ensure that staff are trained on the required verification documents to be collected. 2) Perform periodic review of studen...

The University will review processes to ensure that adequate internal control exists to mitigate risks related to collection of required verification documents are collected. 1) Ensure that staff are trained on the required verification documents to be collected. 2) Perform periodic review of student files to verify completeness of records.

View Audit 39988

Finding 42782 (2022-004)

Significant Deficiency 2022

Chicago State University

IL

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

The University will perform a risk assessment that is inclusive of the requirements outlined in the GLBA.

View Audit 39988

Finding 42773 (2022-001)

Significant Deficiency 2022

Tensas Community Health Center

LA

Cash Management Matching / Level of Effort / Earmarking

Since quarterly reporting is no longer required for HRSA grants in the payment management system, the reconciliation process was unfortunately disrupted. TCHC board of directors and management will review and revise the current cash management policy and procedure to ensure compliance with 45 CFR 75...

Since quarterly reporting is no longer required for HRSA grants in the payment management system, the reconciliation process was unfortunately disrupted. TCHC board of directors and management will review and revise the current cash management policy and procedure to ensure compliance with 45 CFR 75.302(b)(6) and 45 CFR 75.305, as well as, detail a procedure for reconciling drawdowns on a scheduled basis. The procedures will also be designed to ensure improved communication occurs between the individual(s) charged with making drawdowns from the payment management system and the accounting department. The CEO will be responsible for the revised policy and procedure being approved by the board at the February 2023 TCHC board meeting with immediate implementation.

View Audit 39193

Finding 42767 (2022-001)

Material Weakness 2022

Town of Shirley

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2022-001 Contact Person Responsible for Corrective Action: Teresa Hester ? Clerk/Treasurer Contact Phone Number: 765-738-6381 Views of Responsible Official: We concur with finding: As stated in the Finding 2022-001 this finding is also a finding in the 2021-002. All of the transactions were ...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Teresa Hester ? Clerk/Treasurer Contact Phone Number: 765-738-6381 Views of Responsible Official: We concur with finding: As stated in the Finding 2022-001 this finding is also a finding in the 2021-002. All of the transactions were already complete when the 2021 finding was noted. Difficult to change what already was. Internal controls were in place overall with the Grant Writer, Engineering Firm and Clerk/Treasurer, but the town was not provided with direct access to copies of the semi-annual reports. These reports were not accessible because OCRA does not give all unit?s rights to view. (Not being able to have access is where Government Officials should take into consideration when requiring units to be compliant.) Screen shots of the activity were provided to auditor. Description of Corrective Action Plan: The semiannual and other reporting was the responsibility/authority of our grant management. (Town officials have no log-in rights for the records) For future endeavors moving forward we will be implementing a more efficient internal controls. Collaborating with the grant management in knowing when the reports are being filed and that the Clerk/Treasurer is sent a copy of the reports for review. Anticipated Completion Date: This particular project has been finalized, therefore there is no an anticipated completion date. For future endeavors we will implement a more detailed and diversified internal controls process.

View Audit 39079

Finding 42743 (2022-002)

Significant Deficiency 2022

County of Stanislaus

CA

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2022-002 Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that that County establish an internal control process for reviewing and approving indirect costs allocated in accordance with Uniform Guidance. Explanation of disagreement with audit finding: There is n...

2022-002 Significant Deficiency in Internal Control over Compliance Recommendation: We recommend that that County establish an internal control process for reviewing and approving indirect costs allocated in accordance with Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Regarding the review of indirect costs, management acknowledges that our internal control documentation fell short of the necessary standards. While the County?s documents effectively track the indirect costs associated with State and Local Fiscal Recovery Funds (SLFRS), management recognize that we were not utilizing the de minimis rate rule calculations as prescribed by federal regulations. Going forward, the County will ensure that the indirect costs are in full compliance with the de minimis rate rule. The County have established robust controls over indirect costs for SLFRS to mitigate any potential discrepancies and ensure that we are in alignment with federal guidelines by tracking the de minimis indirect cost rates using various spreadsheets and review by multiple approvers. Name(s) of the contact person(s) responsible for corrective action: Jian Ou-Yang Planned completion date for corrective action plan: December 31, 2023

View Audit 41890

Finding 42732 (2022-001)

Material Weakness 2022

The George E. Brown United States-Mexico Foundation for Science

DC

Matching / Level of Effort / Earmarking

Reference Number 2022-001 / Compliance and IC over Compliance CFDA 66.202 Environmental Protection Agency Endowment Criteria: Per Endowment agreement and the related law establishing the Organization, the Organization was to obtain a one-to-one match from sources within Mexico for any contributions ...

Reference Number 2022-001 / Compliance and IC over Compliance CFDA 66.202 Environmental Protection Agency Endowment Criteria: Per Endowment agreement and the related law establishing the Organization, the Organization was to obtain a one-to-one match from sources within Mexico for any contributions made by U.S. government agencies. Condition Found: On September 26, 2011, the Organization obtained a match from the Instituto Mexicano de la Propiedad Industrial ?IMPI? on behalf of the Mexican government. The match was in Mexican Peso equivalent of $5 million US Dollars based on that day?s exchange rates published on the date of the agreement by the Banco de Mexico in the Diario Oficial de la Federacion. During April 2020 IMPI notified the Organization that they will no longer provide the matching funds due to economic hardship related to covid 19. Context: The condition noted was identified as part of our review of federal awards. Effect: The Organization is in non-compliance with match requirements. Cause: IMPI will no longer match the funds due to economic hardship related to covid 19. Recommendation: It is recommended the Organization seek additional contributions sourced within Mexico. In addition, the Organization should contact the federal awarding agency to discuss possible alternative resolutions to this finding. Corrective Action: The Foundation pursued legal action as the way IMPI withdrew from our agreement was found illegal. The court in Mexico agreed with our position and by the end of 2021 the Foundation was notified with a favorable resolution on the lawsuit submitted in 2020, which led to initial meetings with IMPI?s renewed top management about restructuring the support programs that their contribution to our endowment would allow to fund, and with that to reestablish the agreement?s functionality. In June 2022 the Foundation submitted a formal request to IMPI to reset the funds to continue the functioning of the agreement since an addendum was legally developed to be added to the original agreement. Hectic changes in top management at the Ministry of Economy of Mexico and IMPI occurred in 2022, which has resulted in unproductive efforts from previous negotiations. Due to the latter, in July 2023, the Foundation has submitted a second lawsuit, accepted by the court, to enforce the previous one, won in 2021. IMPI has to respond with its official position to the court by the end of August 2023; the Foundation is expecting, based on its lawyer?s opinion, a positive outcome on the evidence analysis and final resolution of this lawsuit. Legal actions will be ending soon, and the Foundation and its Board of Governors would know what the next course of action and a concrete timeframe will be if the Foundation?s obtains a favorable result. Proposed completion date ? By the end of 2023 or 1Q2024. Contact person ? Eugenio Marin, Executive Director

View Audit 41889

Finding 42731 (2022-001)

None 2022

Florida Agricultural & Mechanical University Federal Credit Union

FL

Matching / Level of Effort / Earmarking

B. CORRECTIVE ACTION Credit Union will be recognizing grant revenue in conjunction with the loans granted in the future.

View Audit 48288

Finding 42730 (2022-001)

Material Weakness 2022

St. Vincent Charity Medical Center and Subsidiaries

OH

Subrecipient Monitoring Material Weakness Reporting § 200.303

Finding Number: 2022-001 Condition: In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds, the terms and conditions of the grant, according to U.S. Depar...

Finding Number: 2022-001 Condition: In order to comply with program rules, nonfederal entities must establish and maintain effective internal controls over the federal award, as prescribed by 2 CFR 200.303(a). For Provider Relief Funds, the terms and conditions of the grant, according to U.S. Department of Health and Human Services (HHS), require that the System report certain information accurately into the HHS PRF Reporting Portal in order to attest to the utilization of the funding received. Specifically, the HHS June 11, 2021, post-payment reporting notice provides specific guidance on the calculation of lost revenue and amounts to be reported in the portal. Planned Corrective Action: Chief Financial Officer will insure that all guidance available for PRF reporting (FAQ's etc.) is reviewed prior to making any further submissions to the portal and that the Chief Financial Officer will review the filings with the preparer prior to submissions. Contact person responsible for corrective action: Chief Financial Officer Anticipated Completion Date: August 1, 2023

View Audit 46954

Finding 42729 (2022-001)

Significant Deficiency 2022

Community Development Resources

NE

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

Plan of Action - Implement an interest rate verification process before issuance of loan closing documents. Proposed Completion Date - June 30, 2023

View Audit 46953

Finding 42728 (2022-002)

Significant Deficiency 2022

Community Development Resources

NE

Allowable Costs / Cost Principles Special Tests & Provisions Reporting

Plan of Action - Revise internal controls and processes related to time tracking and grant reporting to ensure complete and accurate records. Proposed Completion Date - June 30, 2023

View Audit 46953

Finding 42727 (2022-004)

Material Weakness 2022

Greene County

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

Finding: 2022-004 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: The Greene County Auditor?s office will establish and mainta...

Finding: 2022-004 Contact Person Responsible for Corrective Action: Heather N Perry, Greene County Auditor Contact Phone Number: 812-384-8658 Views of Responsible Official: We concur with the finding. Description of Correction Action Plan: The Greene County Auditor?s office will establish and maintain effective internal controls over the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Lori Dawn Dickinson will review the P&E Report to verify that all entries are accurate and true, and I (Heather Perry) will submit the report. Heather Perry Greene County Auditor Anticipated Completion Date: April 30, 2024

View Audit 46952

Finding 42671 (2022-002)

None 2022

University of Dubuque

IA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Finding: The University incorrectly calculated Federal Direct Subsidized Loan funds for one student resulting in an under award. Corrective Actions Taken or Planned: The Associate Director of Student Financial Aid reviews each student?s need-based aid to correctly calculate the amount of Direct Sub...

Finding: The University incorrectly calculated Federal Direct Subsidized Loan funds for one student resulting in an under award. Corrective Actions Taken or Planned: The Associate Director of Student Financial Aid reviews each student?s need-based aid to correctly calculate the amount of Direct Subsidized Loan each student should receive, with the TEACH Grant being treated as non-need-based aid. In addition, the Associate Director of Student Financial Aid will reassess a student?s calculation when summer term is awarded. The internal policies and procedures have been updated to ensure the need-based calculations are properly performed and reviewed. Person Responsible: Sara Sroka (ssroka@dbq.edu) Anticipated completion date: 10/19/2022

View Audit 53483 Questioned Costs: $1

Finding 42670 (2022-001)

Significant Deficiency 2022

University of Dubuque

IA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar?s Office submits a monthly report to the National Student Loan Clearinghouse. For a brief period of time the process fo...

Finding: The University did not timely or accurately report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: The Registrar?s Office submits a monthly report to the National Student Loan Clearinghouse. For a brief period of time the process for this was inconsistent. After a review of the procedures the issue has been fixed. Also, to ensure withdrawn dates during the semester are being reported on a timely basis Financial Planning will manually enter dates of withdrawn students to National Student Loan Data Systems (NSLDS). Students who have withdrawn at the end of the semester will be manually entered and monitored closely by the Registrar?s Office who will adjust reporting schedule to ensure timely reporting of withdrawn dates. Person Responsible: Sara Sroka (ssroka@dbq.edu) Anticipated completion date: 10/19/2022

View Audit 53483

Finding 42669 (2022-004)

Significant Deficiency 2022

Tennessee Pharmacists Research and Education Foundation

TN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles

2022-004: Compliance with Cost Principles U.S. Department of Health and Human Services, pass-through State of Tennessee Department of Health - Immunization Cooperative Agreements (ALN COVID-93.268) Management?s Response: We concur. View of Responsible Officials and Corrective Action: The CEO and the...

2022-004: Compliance with Cost Principles U.S. Department of Health and Human Services, pass-through State of Tennessee Department of Health - Immunization Cooperative Agreements (ALN COVID-93.268) Management?s Response: We concur. View of Responsible Officials and Corrective Action: The CEO and the Controller have implemented a process to ensure all staff attributed to the grant are submitting a monthly report of their time attributed to grant work. These timesheets are reviewed by the CEO with a double check by the Controller. The Controller will be revising prior attributions of rent expenses based on percentage of attributed staff timesheets. Anticipated Completion Date: Effective July 1, 2023, all current and new staff have been properly trained on the new process for submitting their monthly time sheets. With new accounting software being implemented on October 1, 2023, the correction to the rent expense accounting will be correctly attributed by November 1, 2023. Name of Responsible Person: The CEO and the Controller.

View Audit 53470

Finding 42668 (2022-003)

Material Weakness 2022

Tennessee Pharmacists Research and Education Foundation

TN

Cash Management Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

2022-003: Compliance with Cash Management Requirements U.S. Department of Health and Human Services, pass-through State of Tennessee Department of Health - Immunization Cooperative Agreements (ALN COVID-93.268) Management?s Response: We concur. View of Responsible Officials and Corrective Action: ...

2022-003: Compliance with Cash Management Requirements U.S. Department of Health and Human Services, pass-through State of Tennessee Department of Health - Immunization Cooperative Agreements (ALN COVID-93.268) Management?s Response: We concur. View of Responsible Officials and Corrective Action: The CEO and the Controller have implemented a process to submit reimbursement for prior month?s work by conclusion of the following month. The Controller has implemented a process to aggressively follow-up with the state accounting team to ensure the state is holding true to a proper timeline of reimbursement. The Controller utilizes this follow-up messaging to the state to ensure all proper documentation has been assessed properly at each stage of the state?s review process. Anticipated Completion Date: TPREF has implemented this new process as of July 1, 2023.

View Audit 53470

Finding 42633 (2022-001)

Significant Deficiency 2022

Quinnipiac University

CT

Student Financial Aid Matching / Level of Effort / Earmarking

As part of the assignment of Perkins Loans, we noted that the assignment process required the submission of original promissory notes for each loan to be assigned. As a result, the University began collecting and digitizing its historic loan records to maintain copies for retention and compliance pu...

As part of the assignment of Perkins Loans, we noted that the assignment process required the submission of original promissory notes for each loan to be assigned. As a result, the University began collecting and digitizing its historic loan records to maintain copies for retention and compliance purposes. The assignment process is currently underway and is required to be completed by June 30, 2023. The University is on track to meet that federal imposed deadline. Quinnipiac University agrees with the finding. A small percentage of the remaining loans to be assigned originated over 10 years ago. As it relates to this finding, we were unable to locate promissory notes for six students with loans originated 10 to 30 years ago. Due to their age, we believe the finding may be related to office moves and departmental reorganizations over the years. As a result of this finding and the federal assignment process in general, Management and Financial Aid have performed a comprehensive review of the remaining student records waiting to be assigned for completeness. As a result of this review Management and Financial Aid have identified all loans that are missing original promissory notes. As part of the assignment process, in lieu of original promissory notes alternative documents supporting the existence of these loans have been provided to the Perkins loan assignment processor. Any loans that are not accepted during this appeals process will be purchased by the University at the conclusion of the assignment process, which is planned to be completed by June 30, 2023. If the Office of Management and Budget have questions regarding this plan, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

View Audit 47260

Finding 42629 (2022-001)

Material Weakness 2022

Ivy Tech Community College of Indiana

IN

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

FINDING 2022-001 Contact Person Responsible for Corrective Action: Colby Shank Contact Phone Number: 317-921-4765 Views of Responsible Official: Ivy Tech Community College disputes this audit finding. The College has an effective internal control system to ensure compliance with requirements relate...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Colby Shank Contact Phone Number: 317-921-4765 Views of Responsible Official: Ivy Tech Community College disputes this audit finding. The College has an effective internal control system to ensure compliance with requirements related to the Special Tests and Provisions ? Return of Title IV Funds compliance requirement. The College previously determined that the Return of Title IV Funds (R2T4) is high-risk due to the large number of transactions, the College?s modular term-based system, and the manual nature of R2T4 calculations. Therefore, a robust quality control review process was implemented. College personnel regularly monitor the error rates and nature of errors discovered through the quality control review to identify, correct, and eliminate calculation errors. The claimed errors outlined in Finding 2022-001 relate to the interpretation of how a correction recalculation is determined. In correction calculations, aid previously returned as a result of the initial calculation in the 2021-2022 academic year was considered no longer disbursed and was included in the correction calculation as ?aid that could have been disbursed.? In certain scenarios, this can result in different return amounts than if the aid had been included in the calculation as ?aid disbursed.? In the absence of explicit guidance on how to handle these scenarios within the Federal Student Aid Handbook, College interpretation and precedent has been to treat aid previously returned under the original calculation as aid that could have been disbursed. Volume 5, Chapter 2 of the 2021-2022 Federal Student Aid Handbook states that ?any undisbursed Title IV aid for the period that the school uses as the basis for the R2T4 calculation is counted as aid that could have been disbursed.? Ivy Tech confirmed this interpretation as valid via a third-party financial aid expert who facilitated a discussion with a representative of the USDOE. This USDOE representative confirmed the accuracy of the calculation and the alignment with the Federal Student Aid Policy Implementation and Oversight Directorate. During this discussion, the representative stated that the results of the original calculation could not be ignored, and that including aid that is no longer disbursed as ?aid that could have been disbursed? is the proper way to perform a correction calculation. The auditors state the College should have performed the following actions: ?The College should have considered the original amount of aid to be returned that had already been posted to each student?s account. The College should have posted the additional amount of aid to be returned to the students? accounts based upon the net difference between the original calculation and the corrective calculation performed for each student.? This methodology would have produced inaccurate return amounts under the interpretation of guidance from Federal Student Aid from which the College was operating during the review period. Only posting the ?net difference? between the original calculation and the correction calculation would have resulted in too few funds being returned to Federal Student Aid for many calculations during the review period. Specifically, a difference in return amounts occurred when the amount of unearned charges (institutional charges for the period multiplied by the percentage of unearned Title IV aid) was less than the calculated amount of Title IV aid to be returned. Under the R2T4 calculation formula, the amount of unearned charges can effectively create a ?cap? on the amount of Title IV aid to be returned by the school. At Ivy Tech Community College, this cap is most often reached when students receive disbursements of federal student loans prior to withdrawing. Because a relatively small percentage of Ivy Tech students receive federal student loans, most correction calculations performed during the review period by Ivy Tech under our interpretation of the guidance resulted in accurate return amounts. This issue only impacted a subset of students who received a correction calculation during the review period. Description of Corrective Action Plan: Upon receiving new guidance from the Chicago/Denver regional office of Federal Student Aid, Ivy Tech has modified the way in which it performs R2T4 correction calculations. Aid returned as a result of the original calculation will remain in the correction calculation as ?aid disbursed? instead of ?aid that could have been disbursed.? The College is no longer following prior guidance received by an expert consultant, a representative of Federal Student Aid that advised the College to include aid that has already been returned as ?aid that could have been disbursed.? The calculation change will be monitored for correctness through the College?s previously established internal controls and quality assurance process for the R2T4 process. Financial aid staff have been trained on the calculation change. Ivy Tech will review all students during the review period who received a correction calculation and will cover with institutional aid any federal grant aid that otherwise would not have been returned under the new guidance from Federal Student Aid. Anticipated Completion Date: 3/31/2023

View Audit 43389

Finding 42615 (2022-001)

Significant Deficiency 2022

Elizabeth James Senior Housing

WA

HUD Housing Programs Special Tests & Provisions Cash Management

Contact Person(s): Hilary Prinz, Accounting Manager, 206-687-4080 Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Due to turnover of staff the residual receipt payment in the amount of $83,818 for 2021 audit was not ...

Contact Person(s): Hilary Prinz, Accounting Manager, 206-687-4080 Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Due to turnover of staff the residual receipt payment in the amount of $83,818 for 2021 audit was not made in 2022. Corrective action planned: The entire finance team has been familiarized with Elizabeth James residual receipt requirement. If there is staff turnover in the future everyone on the team is aware of the requirement. A repeating event reminder has been entered into the property accountant?s calendar, the property asset manager?s calendar, and the finance calendar causing multiple alerts to multiple people within the organization going forward. Anticipated completion date: The 2021 residual receipt deposit requirement in the amount of $83,818.00 was paid via check on March 20, 2023. Repeating calendar events have been completed as of March 29, 2023.

View Audit 44080

Finding 42612 (2022-001)

Material Weakness 2022

Scripps Health and Affiliates

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring

Finding 2022-001: Additional internal controls to ensure payroll expenditures are reviewed were implemented in late FY22 by adopting a new approach to ensure compliant timekeeping. The new approach includes the following steps: ? Revised the current timekeeping policy to clarify employee and mana...

Finding 2022-001: Additional internal controls to ensure payroll expenditures are reviewed were implemented in late FY22 by adopting a new approach to ensure compliant timekeeping. The new approach includes the following steps: ? Revised the current timekeeping policy to clarify employee and manager responsibilities ? Modified failure to comply provisions ? Deployed educational programs for both management and staff ? Reviewed/improved Kronos Time and Attendance system automated notifications ? Made training resources available to management and staff via our Scripps intranet site Leadership monitors policy compliance by individual employee and manager via systemwide reporting on a biweekly basis. Contact person: Eric Cole Expected Completion Date: Completed ? September 2022

View Audit 40148

Finding 42611 (2022-002)

Material Weakness 2022

Scripps Health and Affiliates

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Reporting

Finding 2022-002: Additional internal controls to ensure payroll expenditures are reviewed were implemented in late FY22 by adopting a new approach to ensure compliant timekeeping. The new approach includes the following steps: ? Revised the current timekeeping policy to clarify employee and mana...

Finding 2022-002: Additional internal controls to ensure payroll expenditures are reviewed were implemented in late FY22 by adopting a new approach to ensure compliant timekeeping. The new approach includes the following steps: ? Revised the current timekeeping policy to clarify employee and manager responsibilities ? Modified failure to comply provisions ? Deployed educational programs for both management and staff ? Reviewed/improved Kronos Time and Attendance system automated notifications ? Made training resources available to management and staff via our Scripps intranet site Leadership monitors policy compliance by individual employee and manager via systemwide reporting on a biweekly basis. Contact person: Eric Cole Expected Completion Date: Completed ? September 2022

View Audit 40148

Finding 42608 (2022-004)

Significant Deficiency 2022

Saint Mary's College of California

CA

Questioned Costs Student Financial Aid Reporting

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-004: Significant Deficiency - Non-compliance with Reporting Requirements for Disbursements Condition/Context: For 2 of 25 students selected for testing, the disbursement dates did not agree between the student?s institutional acc...

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-004: Significant Deficiency - Non-compliance with Reporting Requirements for Disbursements Condition/Context: For 2 of 25 students selected for testing, the disbursement dates did not agree between the student?s institutional account and the data reported to COD. The students had disbursements that were later refunded. It was noted that the students were disbursed without a valid MPN on file, resulting in students being disbursement that were not eligible at the time of disbursement. The College ultimately obtained the signed valid MPNs and then re- disbursed the funds, as a result the student account original disbursement date and the COD disbursement date differ. Actions Taken: To ensure that this problem does not recur for 2022-2023, disbursement rules have been instituted in Colleague that would prevent funds disbursing if a student hasn?t completed an MPN. The frequency of exports from Colleague to COD has been increased. In addition, Direct Loan and Pell rejects are being corrected each week so that if funds are disbursed and a Colleague or COD error is received, the disbursement is corrected and re- exported before the 15-day time limit. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023

View Audit 38194 Questioned Costs: $1

Finding 42606 (2022-002)

Significant Deficiency 2022

Saint Mary's College of California

CA

Questioned Costs Student Financial Aid Cash Management

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-002: Significant Deficiency ? Direct Loan Reconciliation Condition/Context: The College was not able to provide the three monthly reconciliations for November 2021, February 2022, or April 2022 when requested for the audit in the ...

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-002: Significant Deficiency ? Direct Loan Reconciliation Condition/Context: The College was not able to provide the three monthly reconciliations for November 2021, February 2022, or April 2022 when requested for the audit in the summer of 2022. The Institution noted that the reconciliations had not been performed timely, and subsequently the Institution had a consultant complete these reconciliations. The auditors were unable to obtain evidence of or confirmation from the Institution on if review of the reconciliations occurred. The sample was not a statistically valid sample. Additionally, the College discovered that Direct Loan reconciliation hadn't been done correctly in the past due to staff turnover. A consultant was given the task of doing a complete 21-22 reconciliation in June 2022. This consultant discovered 16 students had been awarded $177,816 in error. The cause of this was that rules had not been setup correctly in Colleague, and consistent reconciliation by correcting Colleague and COD errors wasn't completed in a timely manner. The auditors obtained the listing of students awarded incorrectly. Actions Taken: For the $177,816in direct loans incorrectly disbursed that was identified, SMC returned the loans and replaced with institutional aid for the impacted students. Beginning with July 2022, the Assistant Director/Systems Specialist reconciles direct loans every month. The Executive Director of Financial Aid and the VP of Enrollment Management review these reports at the end of each month. In addition, a system adjustment has been implemented for 2022-2023 to ensure reconciliation is done monthly. The Assistant Director/Systems Specialist utilizes Colleague variance reports that tract Direct Loans disbursed year to date, the number that COD (Servicer for U.S. Department of Education) has approved, and the students that make up the variance, if any. In addition, COD and Colleague errors that occur during the import/export of Direct Loans to and from COD are corrected on a consistent basis. Reconciliation documentation is then forwarded to the Executive Director for review. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023

View Audit 38194 Questioned Costs: $1

Finding 42592 (2022-006)

Significant Deficiency 2022

Saint Mary's College of California

CA

Internal Control / Segregation of Duties Student Financial Aid Reporting § 200.303

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-006: Significant Deficiency ? Control Environment Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with fede...

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-006: Significant Deficiency ? Control Environment Condition/Context: It was noted during the audit, that there were gaps in the internal control structure of the College, that was no longer adequate to ensure compliance with federal regulations and compliance requirements. Action Taken: The staffing changes in the Business Office and the Financial Aid office resulted in learning curves for the new employees. Both offices have started projects to document procedures so that when turnover occurs, there is a blueprint in place to assist the new employees. SMC will also review the internal controls in place for federal reporting to determine how they can be strengthened. Name(s) of Contact Person Responsible for Corrective Action: Nicole Yu, AVP/Controller and Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion dates: Documenting procedures is on ongoing project. Revised internal controls for federal reporting will be in place by June 30, 2023.

View Audit 38194

Finding 42591 (2022-003)

Significant Deficiency 2022

Saint Mary's College of California

CA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-003: Significant Deficiency - Enrollment Reporting Condition/Context: Of 25 students tested, the status date for one student selected was not reported accurately on the campus level reporting in National Student Loan Data System ...

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-003: Significant Deficiency - Enrollment Reporting Condition/Context: Of 25 students tested, the status date for one student selected was not reported accurately on the campus level reporting in National Student Loan Data System (NSLDS). The College used the degree conferral date of 8/20/2021 rather than the end of the term/last date of attendance of July 4, 2021 that was used for reporting program level information for this student, and consistent with how other students were reported. Additionally, for two students, reporting at the program level was late, not within 30 days or included in a response to a roster file or within 60 days. The students were reported as graduated effective August 20, 2021 with the earliest certification date of October 31, 2021 at the campus level and December 3, 2021 at the program level. Action taken: In order to ensure compliance in 2022-2023, the Office of the Registrar has increased the degree of reporting frequency to National Student Clearinghouse (NSC), so as to meet the 60-day requirement in NSLDS. It has also have gained access to the National Student Loan Data System to monitor alignment with information submitted by SMC to NSC. Name(s) of Contact Person Responsible for Corrective Action: Tracey Donaldson, AVP and Registrar Anticipated Completion date: June 30, 2023

View Audit 38194

Finding 42590 (2022-001)

Significant Deficiency 2022

Saint Mary's College of California

CA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-001: Significant Deficiency- Return of Title IV Funds Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reporte...

Corrective Action Plan for the Year Ended June 30, 2022 Finding 2022-001: Significant Deficiency- Return of Title IV Funds Condition/Context: During the audit it was noted that the College provided a list of students that withdrew during the fiscal year and this differed from data that was reported internally to the Audit Committee on the number of students that withdrew in Fall 2021 and Spring 2022 (through April). The number of students that withdrew, the number of student?s that required an R2T4 calculation and the amount of the return all varied. The auditors discussed this with management who confirmed that the list provided to the auditors was complete and that the information reported to the Audit Committee was incorrect. From the withdrawal population the College did provide, a sample of 9 students were selected for testing for return of Title IV funds, of which 5 students did not require Title IV refunds and 4 students did require Title IV refunds. For the population of students with Title IV refunds, the calculations and refunds for 3 students were performed late, and for 1 of those students the calculation was also incorrect (excluded SEOG funds from the calculation). For the 3 students with refunds that were late, 100% of their Title IV funds were returned and then later re- disbursed before the R2T4 calculation and return occurred. Actions Taken: Subsequent to the 2021-2022 single audit fieldwork, SMC had a Financial Aid Services consultant review all R2T4 cases and 1 additional error was identified requiring the return of an additional $17.00. In the future, all R2T4 refund calculations will be performed by the Assistant Director/Systems Specialist who has received substantial training. In addition, the Assistant Director?s refund calculations will be reviewed by the Executive Director of Financial Aid for accuracy. System adjustments have also been made so that if funds are reversed they are re-disbursed at the amount the student is eligible for after the R2T4 calculation is completed. Name(s) of Contact Person Responsible for Corrective Action: Joseph Gilchrist, Interim Financial Aid Director Anticipated Completion date: June 30, 2023

View Audit 38194 Questioned Costs: $1

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