Corrective Action Plans

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Identifying Number: 2023-005 Finding: The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. ...
Identifying Number: 2023-005 Finding: The College did not apply the appropriate clock to credit hour conversion formula for certain applicable financial aid eligible programs. The College also did not have sufficient evidence of controls being in place to ensure compliance with this requirement. Corrective Action Planned: Moraine Valley Community College will evaluate all certificates that are standalone programs. Financial Aid will receive a list of these programs and work with IT to identify students enrolled in those programs. Financial Aid will also update our policies and procedures to ensure that all clock to credit hour conversion formulas are being applied and documented per Uniform Grant Guidance (34 CFR 688.8). Anticipated Completion Date: June 30, 2024 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu
Identifying Number: 2023-001 Finding: For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60-day requirement. Corrective Action Plann...
Identifying Number: 2023-001 Finding: For eight out of ten students tested (80%) who withdrew from the College, the students' status change at the campus level and program level was not reported to the National Student Loan Data System (NSLDS) within the 60-day requirement. Corrective Action Planned: Enrollment Services staff have created a shared logbook that will track and compile NSC transactions. This logbook is saved to a shared drive with access given to appropriate staff, VP of Student Development and Dean of Enrollment Services. Additionally, any extended gaps in reports being verified, submitted and/or responses by either College staff or NSC staff will be followed up with by the Assistant Dean of Enrollment Services and logged in the NSC logbook for audit purposes. Anticipated Completion Date: June 30, 2024 Responsible Person: Tasha Campbell, Director of Financial Aid campbellt68@morainevalley.edu
The accounting department, under direction of the CFO, will conduct monthly audits of random patients' accounts for whom the sliding fee schedule has been applied, as well as training for receptionist to minimize errors. Receptionists have been mandated, along with assistance from internal billing s...
The accounting department, under direction of the CFO, will conduct monthly audits of random patients' accounts for whom the sliding fee schedule has been applied, as well as training for receptionist to minimize errors. Receptionists have been mandated, along with assistance from internal billing staff, to review all patients' accounts (including income verification) at least annually.
Finding 524 (2023-002)
Significant Deficiency 2023
Corrective Action Plan for Finding 2023-002 - The University has provided additional training and instruction to our Student Accounts representatives and will make modification to the disbursement process to ensure that credit balances resulting from federal student financial aid are refunded to the...
Corrective Action Plan for Finding 2023-002 - The University has provided additional training and instruction to our Student Accounts representatives and will make modification to the disbursement process to ensure that credit balances resulting from federal student financial aid are refunded to the student in compliance with the 14-day requirement. The corrective action was implemented Setember 5, 2023 by Jenny Cox, Director of Student Accounts.
Finding 519 (2023-001)
Significant Deficiency 2023
Corrective Action Plan for Finding 2023-001 - The University experienced turnover in the Institutional Research position that attributed to the reporting errors. The University will provide additional training and monitoring to ensure that information reported to the National Student Loan Data Syst...
Corrective Action Plan for Finding 2023-001 - The University experienced turnover in the Institutional Research position that attributed to the reporting errors. The University will provide additional training and monitoring to ensure that information reported to the National Student Loan Data System (NSLDS) is timely and accurate. The University also has a team represented by personnel from the Financial Aid office and Registrar's office that are evaulating our third-party agent assisting with enrollment verification reporting to the NSLDS, and the University will make a change in that relationship if warranted. The corrective action is currently in process and is being coordinated by Michelle Otwell, Assistant Professor and University Registrar; Breanna Yarbrough, Assistant Professor and Director of the Center for Assessment, Research, Effectiveness & Enhancement (CAREE); Linda Pynes, Director of Financial Aid. The corrective training will be completed immediately and monitoring will be an ongoing activity. The decision on whether to make a change in the agent assisting with transmitting data to the NSLDS will be made before May 31, 2024.
The Global Learning Charter Public School Administration and Board of Trustees acknowledge that the limitations present with the segregation of financial duties are the direct result of the size of the school’s financial operation. Over the next year, GLCPS will be undergoing a change in leadership ...
The Global Learning Charter Public School Administration and Board of Trustees acknowledge that the limitations present with the segregation of financial duties are the direct result of the size of the school’s financial operation. Over the next year, GLCPS will be undergoing a change in leadership that will provide the school with greater opportunity to enhance internal financial oversight, further augmenting existing procedures. GLCPS will continue evaluating these procedures and implementing changes as recommended. The Global Learning Charter Public School Foundation will also be reviewing the composition of its Board of Directors to clearly delineate the roles and responsibilities of its members.
Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A review is being completed by the Registrar’s Office to determine if something is in the student record that may prevent a student from being reported correctly. If a common factor can be determined, then ...
Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: A review is being completed by the Registrar’s Office to determine if something is in the student record that may prevent a student from being reported correctly. If a common factor can be determined, then it will be corrected. Until then, Enrollment reporting to NSC will be reviewed twice. Follow up will be done regarding last date of attendance reporting for those students who do fail to complete the semester. Person Responsible for Corrective Action Plan: Karen LaQuey, Director, Student Financial Aid Director; Wendy McNeeley, previous Registrar; Kristina Penland, Registrar Anticipated Date of Completion: 12/12/2023
Views of responsible officials and planned corrective actions: The Financial and Data Analytics Director conducts spot testing of each bi-weekly payroll expenditure report received from Human Resources for eligible PRF reporting. Evidence of testing is retained. Responsible Officials: Dean C. Cocchi...
Views of responsible officials and planned corrective actions: The Financial and Data Analytics Director conducts spot testing of each bi-weekly payroll expenditure report received from Human Resources for eligible PRF reporting. Evidence of testing is retained. Responsible Officials: Dean C. Cocchi, Vice President and CFO Completion Date: March 31, 2022
Recommendation: JTCHS should review federal procurement guidelines and revise its procurement policy to be in compliance with the federal procurement guidelines. Responsible Official’s Response: Management will review adopt a procurement policy in accordance with the Uniform Guidance. Planned Implem...
Recommendation: JTCHS should review federal procurement guidelines and revise its procurement policy to be in compliance with the federal procurement guidelines. Responsible Official’s Response: Management will review adopt a procurement policy in accordance with the Uniform Guidance. Planned Implementation Date of Corrective Action Plan: Management has started revising its policy and expects to have a revised procurement policy during fiscal year ending January 31, 2024.
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: An incorrect date was used to process one student’s Return of Title IV (R2T4) calculation. Training has been provided to financial aid staff in properly performing the R2T4 calculations and a ...
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: An incorrect date was used to process one student’s Return of Title IV (R2T4) calculation. Training has been provided to financial aid staff in properly performing the R2T4 calculations and a report is being run several times a month to identify possible data entry errors in R2T4 calculations. Anticipated Completion Date: Completed
View Audit 719 Questioned Costs: $1
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: The majority of the certification delays were one day late. Corrective action has been taken. The financial aid office is working jointly with the registrar’s office to report enrollment infor...
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: The majority of the certification delays were one day late. Corrective action has been taken. The financial aid office is working jointly with the registrar’s office to report enrollment information via the National Student Clearinghouse (NSC) which will facilitate more timely reporting of future enrollment status changes to NSLDS and reporting of all significant data elements to NSLDS. Reporting to NSC by the University Registrar’s Office has begun. Anticipated Completion Date: Completed
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: This finding affected a mere 2 of 40 records tested. Corrective action has been taken. The financial aid office has set up daily disbursement record submissions through its financial aid proce...
Name of Responsible Individual: Sarah Christoffersen, Interim Director of Financial Aid Corrective Action: This finding affected a mere 2 of 40 records tested. Corrective action has been taken. The financial aid office has set up daily disbursement record submissions through its financial aid processing system, Jenzabar Financial Aid, which will simplify the process and prevent reporting delays. Anticipated Completion Date: Completed
Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: This instance was an administrative error. Measures are in place to process refunds on a weekly basis. Anticipated Completion Date: Refund processing will be monitored on an ongoing basis.
Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: This instance was an administrative error. Measures are in place to process refunds on a weekly basis. Anticipated Completion Date: Refund processing will be monitored on an ongoing basis.
Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: The University Financial Aid Office has restructured the disbursement process as noted below: • Staff members will be retrained on the importance of timely reporting and record compliance. • A disbursement and docum...
Name of Responsible Individual: Ruth Casper & Stephanie Furlough Corrective Action: The University Financial Aid Office has restructured the disbursement process as noted below: • Staff members will be retrained on the importance of timely reporting and record compliance. • A disbursement and documentation process will be created to track, manage and reconcile the disbursement requests sent to COD. This process will aidin recognizing approved disbursements, rejected requests, and posting of disbursements. • The disbursement and reconciliation log will be reviewed by the Asst. Vice President for Student Financial Services as well as the Asst Vice President for Analytics & Audit. Anticipated Completion Date: The disbursement procedures will be monitored on an ongoing basis.
The enrollment reporting issue specifically relates to the integrated BS/PharmD degree program. The University's primary operating system, Jenzabar, reports concurrent enrollment status for P1 students and students who have graduated from the bachelor's degree component of the program. Since the N...
The enrollment reporting issue specifically relates to the integrated BS/PharmD degree program. The University's primary operating system, Jenzabar, reports concurrent enrollment status for P1 students and students who have graduated from the bachelor's degree component of the program. Since the National Student Clearinghouse's (NSC's) system automatically overrides the graduation data in the University's Jenzabar report without notifying the University, a two-step corrective action plan has been initiated. The modified reporting process to improve internal controls consists of the following steps: 1. Upload the initial Jenzabar enrollment reporting into the NSC system which will show full-time enrollment for both the bachelor's degree and the PharmD program; 2. File a second report reflecting the date of completion of the bachelor's degree for all students in the integrated program to remedy the NSC system override of graduation data in the initial Jenzabar report; and 3. Conduct a manual verification of graduation data in the National Student Loan Data System to ensure complete, accurate and timely reporting of graduation information from NSC. The modified reporting process is expected to be fully implemented at the conclusion of the 2023-2024 academic year in conjunction with completion of commencement, which is scheduled to occur in May 2024.
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower ceases at least half-time study. Exit counseling must be conducted within 30 days after th...
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b), (1) & 34 CFR 674.42(b)]. The University concurs with this finding and will adhere to the corrective action plan. Corrective Action: The audit for FY22 was not finalized until June 27, 2023. The plan date for correction for this finding was December 31, 2023. Therefore, the plan was not realized due to the timing of completion of the FY22 audit. Now that the FY23 audit is completed, the Registrar will email exit counseling materials as an attachment to the email or send a email containing URL or hyperlink which will take the student directly to the Exit Counseling page on StudentAid.gov. Responsbile Person(s): Doreen Dixon, Registrar ddixon@vuu.edu 804 257-5845. Robert Merino, Executive Director jrmerino@vuu.edu 281 795-6190. Planned Date of Completion of Corrective Action: December 31, 2023.
Criteria: Under the Pell grant and ED loan programs, Institutions are responsbile for timely enrollment reporting to the NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical...
Criteria: Under the Pell grant and ED loan programs, Institutions are responsbile for timely enrollment reporting to the NSLDS whether they report directly or via a third-party servicer such as the National Student Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective management of the programs. Enrollment information must be reported within 60 days whenever enrollment status changes for students unless a roster is submitted within 60 days. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leave-of-absence. The University concurs with this finding and will adhere to the corrective action plan. Corrective Action: The audit for FY22 was not finalized until June 27, 2023. The plan date for correction for this finding was December 31, 2023. Therefore, the plan was not realized due to the timing of completion of the FY22 audit. Now that the FY23 audit is completed, the Registrar and Information Technology will ensure monthly reporting to the National Clearinghouse. In addition, the Registrar will determine the root cause is corrected and enrollment is reported correctly. These procedures will become part of the Registrar's Standard Operating Procedures. Responsbile Person(s): Doreen Dixon, Registrar ddixon@vuu.edu 804 257-5845. Kofi Jack, Chief Information Officer kjack@vuu.edu 804 257-5709. Planned Date of Completion of Corrective Action: December 31, 2023.
Criteria: Institutions are required to report all Direct Loan (DL) disbursements and submit required records to the Department of Education's Common Origination and Disbursement (COD) which is a web-based system for processing, storing and reconciling DL financial aid data. Each month, the COD provi...
Criteria: Institutions are required to report all Direct Loan (DL) disbursements and submit required records to the Department of Education's Common Origination and Disbursement (COD) which is a web-based system for processing, storing and reconciling DL financial aid data. Each month, the COD provides Institutions with a School Account Statement (SAS) date file which consists of a Cash Summary, Cash Detail and (optional at the request of the school) Loan Detail records. The school is required to reconcile these files to the Insitution's financial records ("DL Reconciliations"). While the University has made significant improvements in this reconciliation process and that of the other related federal award programs, there are still unreconciled differences in all three major federal pass-through program's reonciliations as noted in the financial statement audit. However, for FY23, these differences netted to an immaterial difference overall and were no adjusted / passed during the financial statement audit. However, differences still remain, and the reconciliation process still needs to be improved upon. The University concurs with the audit finding and will adhere to the corrective action plan. Corrective action: The Student Financial Aid activity was reconciled among the Registrar, Financial Aid, and Business Offices as of June 30, 2023, at detailed (student) level. Monthly reconciliations will be maintained effective July 2023. Responsible Person(s): Robert Merino, Executive Director of Financial Aid jrmerino@vuu.edu 218 795-6190. Planned Date of Completion of Corrective Action: December 31, 2023.
Finding 126 (2023-001)
Significant Deficiency 2023
The University did not accurately or timely report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: Based on these circumstances of a reported status being overwritten by a monthly update, we will do a random audit of all reported withdrawn s...
The University did not accurately or timely report enrollment changes to the National Student Loan Data System (NSLDS). Corrective Actions Taken or Planned: Based on these circumstances of a reported status being overwritten by a monthly update, we will do a random audit of all reported withdrawn students to make sure the correct status has flowed through to NSLDS from NSLC Anticipated Completion Date: December 1, 2023 Contact Person: Julie Haack
Finding Reference Number 2022: Untimely Completion of the Single Audit Description of Finding: The Single Audit for the year ended December 31, 2022 was completed approximately three years after the fiscal year-end due primarily to prolonged delays in responses to audit requests and untimely submiss...
Finding Reference Number 2022: Untimely Completion of the Single Audit Description of Finding: The Single Audit for the year ended December 31, 2022 was completed approximately three years after the fiscal year-end due primarily to prolonged delays in responses to audit requests and untimely submission of required supporting documentation. Statement of Concurrence or Nonconcurrence: Threshold CoC concurs with the finding. Corrective Action: Management will establish formal procedures to ensure timely completion and submission of future Single Audits. Procedures will assign an audit coordinator, maintain a centralized tracking system for auditor requests and outstanding items, establish internal deadlines for providing requested documentation, and require regular progress communication with the audit team. Management will also ensure adequate staffing and resources are available throughout the audit process. Name of Contact Person: Jason Feldhaus, Executive Director, jason@thresholdcoc.org Projected Completion Date: December 31, 2026 Questioned Costs: None
Farmers Market and Local Food Promotion Program– Assistance Listing No. 10.175 Recommendation: To implement a documented review and approval for matching transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding...
Farmers Market and Local Food Promotion Program– Assistance Listing No. 10.175 Recommendation: To implement a documented review and approval for matching transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement a quarterly review and approval process for grant matching transactions, performed separately for each grant program. For each program, a spreadsheet summarizing that program's matching transactions received during the prior quarter will be prepared and sent to the Executive Director for review. The Executive Director's approval will be documented via email for each program, retained along with the corresponding supporting spreadsheet as evidence of review. Name(s) of the contact person(s) responsible for corrective action: Rob Smith Planned completion date for corrective action plan: September 30, 2026
Beginning Farmer and Rancher Development Program – Assistance Listing No. 10.311 Recommendation: To provide additional training to employees and supervisors responsible for timesheet preparation and approval to reinforce compliance with established timesheet policies and approval controls. Explanati...
Beginning Farmer and Rancher Development Program – Assistance Listing No. 10.311 Recommendation: To provide additional training to employees and supervisors responsible for timesheet preparation and approval to reinforce compliance with established timesheet policies and approval controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will provide additional training to both employees responsible for preparing timesheets and to supervisors responsible for reviewing and approving them. This training will cover accurate and timely recording of time worked, including proper allocation of time to federal grant programs, and will reinforce Viva Farms' existing timesheet policies and supervisor approval requirements before timesheets are submitted to payroll.. Name(s) of the contact person(s) responsible for corrective action: Rob Smith Planned completion date for corrective action plan: September 30, 2026
DPS has developed a draft Standard Operating Procedures Manual for the newly created fiscal section. This SOP includes: Establishing and documenting formal procedures for the preparation, review, and timely submission of SF-425 reports; implementing a report reconciliation checklist requiring agreem...
DPS has developed a draft Standard Operating Procedures Manual for the newly created fiscal section. This SOP includes: Establishing and documenting formal procedures for the preparation, review, and timely submission of SF-425 reports; implementing a report reconciliation checklist requiring agreement of reported data to PRIFAS andSEFA records, ensure that each report includes federal and recipient share, drawdown activity, and unliquidated obligations as of the reporting date, designate an official responsible for review and approval prior to filing and retain evidence of submission, and DSP will also provide staff training on federal reporting requirements under 2 CFR 200.327-329. This new section will specifically address federal programs for the bureaus and DPS itself.
Managements Corrective Action Plan: Individual(s) Responsible for Corrective Action Plan Tysha Dixon Director, Financial Reporting (215) 496-8168 Completed March 2023 Questioned Program: ALN #14.218 Community Development Block Grants (CDBG) Finding #2022-001 – Activities Allowed or Unallowed and All...
Managements Corrective Action Plan: Individual(s) Responsible for Corrective Action Plan Tysha Dixon Director, Financial Reporting (215) 496-8168 Completed March 2023 Questioned Program: ALN #14.218 Community Development Block Grants (CDBG) Finding #2022-001 – Activities Allowed or Unallowed and Allowance Costs / Cost Principles Information on Federal Program – CDBG Entitlement Grants Cluster, Community Development Block Grants – Entitlement Grants, 14.218, Philadelphia Department of Commerce, contract number 23-20489 Management’s Corrective Action Plan Management will continue to rely on its existing controls that are in place, including the ongoing communication with the City for any changes in transactions that require their approval. In the circumstances where management is pending a contract amendment from the City for loans requiring additional funding, management will determine if there are unrestricted funding sources to support the change in the approved amount of the loan until the amended contract is finalized.
Public and Indian Housing – ALN #14.850 Recommendation: We recommend that management review their procedures to ensure that all required documentation is maintained in the file. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. procedures for tenant inc...
Public and Indian Housing – ALN #14.850 Recommendation: We recommend that management review their procedures to ensure that all required documentation is maintained in the file. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. procedures for tenant income and asset verification to ensure that all required third-party documentation is obtained, retained, and reviewed before certifications are finalized. Supervisory review procedures were enhanced to include verification of income documentation, asset calculations, and tenant file completeness. Staff received refresher training on HUD documentation requirements, income and asset verification procedures, and file quality control standards. In addition, ongoing file audits and management review procedures have been implemented to identify and correct documentation deficiencies promptly. Name(s) of the contact person(s) responsible for corrective action: Jason Epperson, Assistant Vice President Planned completion date for corrective action plan: December 31, 2026
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