Corrective Action Plans

Finding 43036 (2022-004)

Significant Deficiency 2022

King University

TN

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

2022-004 Significant Deficiency: Awarding Eligibility (Federal Pell Grant Program, ALN #84.063) Name of Contact Person: The Director of Financial Aid, Christin Mustard, is responsible for the corrective action of this finding. Financial Aid packaging is performed by the Financial Aid Counselors, who...

2022-004 Significant Deficiency: Awarding Eligibility (Federal Pell Grant Program, ALN #84.063) Name of Contact Person: The Director of Financial Aid, Christin Mustard, is responsible for the corrective action of this finding. Financial Aid packaging is performed by the Financial Aid Counselors, who report to the Director of Financial Aid. Corrective Action Plan: We concur there were instances where King failed to calculate/disburse Federal Pell Grant funds appropriately based on their updated Enrollment Status/EFC. We found that the Pell distribution fund was locked, which prevented the Pell recalculation when the higher ISIR transaction was loaded. In addition, there was not a report in place to alert the Financial Aid office of students enrolled in both traditional and modular courses. As a result, those students were not being identified/monitored effectively for enrollment changes. King is currently updating its policies and procedures to capture and monitor enrollment status of traditional students enrolled in a combination of traditional and modular courses. This will ensure that Pell Grant is awarded correctly based on enrollment status and modular courses for which the student verified. Additionally, we will ensure that Pell Grant award distributions are unlocked so that the Powerfaids system will update the Pell award amounts correctly according to EFC changes from subsequent ISIRs. Anticipated Completion Date: All Pell findings have been reviewed, and errors that could be corrected have been resolved.

View Audit 44218 Questioned Costs: $1

Finding 43035 (2022-002)

Significant Deficiency 2022

King University

TN

Student Financial Aid Reporting Significant Deficiency

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) ?Did not supply status updates to NSLDS in a timely manner. Name of Contact Person: The Direc...

2022-002 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063) ?Did not supply status updates to NSLDS in a timely manner. Name of Contact Person: The Director of Registration and Records, Whitney Cleland, and the Director of Institutional Research and Assessment, Jason Thead, are responsible for the corrective action plan for this finding. Corrective Action Plan: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. Effective Fall 2022, King University will submit enrollment data uploads to the National Student Clearinghouse at least every 30 days. The first of term submission will occur within 21 days of the start date of the term. Monthly enrollment reporting will correspond with module drop/add periods and will occur no later than 10 business days after a module drop period ends, per the Academic Calendar. Additionally, and as a part of the enrollment submission process for the National Student Clearinghouse (NSC), which provides data to NSLDS, an exception report is generated for each enrollment file prior to submission. This exception report is verified and remedied before data is submitted to NSC. Once data is submitted to NSC, an error report is generated from the NSC system. For any students who have status or level changes, the Director of Institutional Research and Assessment verifies all dates with an internal report, called the Enrollment Analysis by Course report, to ensure dates are accurately reported to the NSC. This report is also used by the Office of Financial Aid to ensure withdrawal dates are consistent. This internal report and process ensures that the dates used for all offices are the same, which remedies any communication issues between offices. Additionally, notices are sent by Financial Aid for adjustments to withdrawal dates, which are corrected in our database management system (DBMS). These additional steps allow the DBMS to accurately and collectively capture all applicable students, and the exception and error reports allow the institution to ensure the correct information is reported. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created. Anticipated Completion Date Per above, effective Fall 2022, enrollment data is now uploaded to the National Student Clearinghouse at least every 30 days. Furthermore, the missing fields in the DBMS have been remedied, and the institution is working with NSC and NSLDS to correct previously misreported records by February 2023.

View Audit 44218

Finding 43034 (2022-001)

Significant Deficiency 2022

King University

TN

Student Financial Aid Reporting Significant Deficiency

2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063). Incorrectly reported student enrollment status. Name of Contact Person: The Director of Regi...

2022-001 Significant Deficiency: National Student Loan Data System (NSLDS) Report (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268 and Federal Pell Grant Program, ALN #84.063). Incorrectly reported student enrollment status. Name of Contact Person: The Director of Registration and Records, Whitney Cleland, and the Director of Institutional Research and Assessment, Jason Thead, are responsible for the corrective action plan for this finding. Corrective Action Plan: King University uses the National Student Clearinghouse to report enrollment changes to NSLDS. Effective Fall 2022, King University will submit enrollment data uploads to the National Student Clearinghouse at least every 30 days. The first of term submission will occur within 21 days of the start date of the term. Monthly enrollment reporting will correspond with module drop/add periods and will occur no later than 10 business days after a module drop period ends, per the Academic Calendar. Additionally, and as a part of the enrollment submission process for the National Student Clearinghouse (NSC), which provides data to NSLDS, an exception report is generated for each enrollment file prior to submission. This exception report is verified and remedied before data is submitted to NSC. Once data is submitted to NSC, an error report is generated from the NSC system. For any students who have status or level changes, the Director of Institutional Research and Assessment verifies all dates with an internal report, called the Enrollment Analysis by Course report, to ensure dates are accurately reported to the NSC. This report is also used by the Office of Financial Aid to ensure withdrawal dates are consistent. This internal report and process ensures that the dates used for all offices are the same, which remedies any communication issues between offices. Additionally, notices are sent by Financial Aid for adjustments to withdrawal dates, which are corrected in our database management system (DBMS). These additional steps allow the DBMS to accurately and collectively capture all applicable students, and the exception and error reports allow the institution to ensure the correct information is reported. We believe a portion of the untimely reporting to NSLDS is a result of the reporting delays between the National Student Clearinghouse and NSLDS, as documented in GENERAL-22-64 beginning July 25, 2022. The Dear Colleague letter and subsequent updates describe issues with enrollment functionality, which affected enrollment reporting. King conducted a review on a sample of students and found that students were reported correctly to the Clearinghouse but were not appearing in NSLDS. A more frequent enrollment schedule should remedy this issue. We also attribute these delays to changes in leadership/staffing during that timeframe. The enrollment reporting steps were outlined by the prior Registrar when this process transitioned to the Office of Institutional Research, but this staffing transition could have resulted in inaccurate data being captured and reported during a window of time in Fall 2021 (when the reporting responsibility transitioned). Additionally, it was discovered that incorrect coding in the CAMS database management system (DBMS) was causing exclusions based on a missing field. These exclusions began in Summer 2021 due to added majors that were not correctly created. Anticipated Completion Date Per above, effective Fall 2022, enrollment data is now uploaded to the National Student Clearinghouse at least every 30 days. Furthermore, the missing fields in the DBMS have been remedied, and the institution is working with NSC and NSLDS to correct previously misreported records by February 2023.

View Audit 44218

Finding 43013 (2022-001)

Significant Deficiency 2022

Council of Western State Foresters

CO

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Management Response and Planned Corrective Action We concur with the Federal Award Findings outlined above of the auditors and have implemented a corrective action plan, including updating internal control policies and procedures. Views of Responsible Officials and Corrective Actions The managem...

Management Response and Planned Corrective Action We concur with the Federal Award Findings outlined above of the auditors and have implemented a corrective action plan, including updating internal control policies and procedures. Views of Responsible Officials and Corrective Actions The management team of the Council of Western State Foresters believe in the values of transparency, justification, and documentation for the transactions made while conducting organizational duties, whether funded by federal sources or otherwise. As a small organization with limited staff, suggested reasonable improvements to processes are always welcome. It is in this spirit that the below corrective actions to address the findings and questioned costs noted on the 2022 Single Audit. Corrective Action Plan: 1. The organization?s credit card and the credit card held in the name of the Executive Director are currently one and the same. All credit card transactions are reviewed no less than monthly, and any staff usage of the credit card requires and secures pre-approval. Going forward, the CWSF Credit Card Usage Policy will be adjusted to provide clarity regarding credit card usage by staff and reflect the review process. With any staff usage of the credit card, documentation will be made of pre-approval along with receipt documentation of the purchase. Purchases made by staff will be documented as authorized by the Executive Director. 2. While approvals for these expenditures did occur per both the credit card usage and travel policies, the documentation was not attached with the corresponding receipt. In future, written emails or other approval documenting necessary authorization will be included with the corresponding receipts in the organizational and financial records. 3. Following the discovery of 1 income I-9 in staff personnel files during the course of the audit, a thorough review of all personnel files has already been undertaken to ensure that no other files are missing critical documentation, including I-9s and corresponding proof of identification. Moving forward, all personnel documentation for current and future staff will be maintained in hard copy as well as in electronic form and will be maintained in accordance with legal requirements for document retention.

View Audit 39962 Questioned Costs: $1

Finding 43010 (2022-001)

None 2022

Parker Presbyterian Senior Housing Inc.

PA

Questioned Costs HUD Housing Programs Reporting

A. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation Those charged with governance agree with the finding and recommendation. b. Action Taken or Planned on the Finding Those charged with gove...

A. Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations. 1. Finding 2022-001 a. Comments on the Finding and Each Recommendation Those charged with governance agree with the finding and recommendation. b. Action Taken or Planned on the Finding Those charged with governance have requested a waiver of deposits to the reserve for replacements account from HUD that would apply retroactively to the outstanding deposits for prior years. The Project has made the required monthly deposits for the year ending December 31, 2022.

View Audit 39110 Questioned Costs: $1

Finding 43009 (2022-004)

Significant Deficiency 2022

Northwood Deaconess Health Center

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding 2022-004 Federal Agency Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: There was no informal documented review over the reserve fund reconciliation for the federal program. Responsible Individuals: Pete Antonson, CFO Corr...

Finding 2022-004 Federal Agency Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Finding Summary: There was no informal documented review over the reserve fund reconciliation for the federal program. Responsible Individuals: Pete Antonson, CFO Corrective Action Plan: We have adopted a policy to enhance internal control to ensure the reserve fund reconciliation has a secondary review and approval that is documented. Anticipated Completion Date: October 30, 2023

View Audit 39287

Finding 43007 (2022-003)

Material Weakness 2022

Northwood Deaconess Health Center

ND

Reporting Material Weakness Matching / Level of Effort / Earmarking

Finding 2022-003 Federal Agency Name: Department of Agriculture Department of Health and Human Services Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Rural Health Research Centers Federal Financial Assistance Listing #93.155 Finding Summa...

Finding 2022-003 Federal Agency Name: Department of Agriculture Department of Health and Human Services Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 Rural Health Research Centers Federal Financial Assistance Listing #93.155 Finding Summary: Eide Bailly LLP prepared our schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule. Responsible Individuals: Pete Antonson, CFO Corrective Action Plan: Having auditors assist with preparing the schedule of expenditures of federal awards (SEFA) is not unusual. We will continue to be aware of the financial reporting requirements relating to the Health Center?s schedule of expenditures of federal awards and internal control that impact financial reporting. Anticipated Completion Date: Ongoing

View Audit 39287

Finding 42958 (2022-001)

None 2022

Commissioners of St. Mary's County

MD

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Finding 2022-001 Planned Corrective Action: The grant management duties will be assigned to more than one person to avoid late reports being submitted in the future. Additionally, more than one staff member in Department of Public Works (DPWT) will have the ability to submit reports in the event th...

Finding 2022-001 Planned Corrective Action: The grant management duties will be assigned to more than one person to avoid late reports being submitted in the future. Additionally, more than one staff member in Department of Public Works (DPWT) will have the ability to submit reports in the event the lead grants manager is unavailable. If future reports are expected to be late, the Deputy Director of Finance will be notified as to why the report is late. Name of Contact Person: James Gotsch, Director/Department Head Anticipated Completion Date: The above actions will be implemented before the next quarterly report is due ? by April 30, 2023. The additional assigned staff member(s) for the above noted responsibilities will be reported to the Deputy Director of Finance and Chief Financial Officer by April 30, 2023.

View Audit 43882

Finding 42955 (2022-001)

Significant Deficiency 2022

Flagler College, Inc.

FL

Matching / Level of Effort / Earmarking Significant Deficiency

2022-001 Educational Stabilization Fund ? Earmarking ? HEERF earmarking requirements. Recommendation: We recommend that the College monitor the earmarking requirements of all grants, to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding...

2022-001 Educational Stabilization Fund ? Earmarking ? HEERF earmarking requirements. Recommendation: We recommend that the College monitor the earmarking requirements of all grants, to ensure compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was caused by improper reporting of items earmarked per requirements. Accounting personnel will review grant/award contracts and associated standards in order to create necessary tracking documents to be submitted to individual responsible for grant/award reporting. Flagler is in the process of hiring a dedicated Grants & Compliance Manager that will be responsible for organizing and tracking requirements moving forward. Name(s) of the contact person(s) responsible for corrective action: Stacey Matthews and Tiffany Moore Planned completion date for corrective action plan: March 23, 2023 reporting on earmarking correction; implementation upon next award

View Audit 40194

Finding 42954 (2022-002)

Significant Deficiency 2022

Flagler College, Inc.

FL

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2022-002 Educational Stabilization Fund ? Reporting ? HEERF reporting requirements. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the ...

2022-002 Educational Stabilization Fund ? Reporting ? HEERF reporting requirements. Recommendation: We recommend that the College review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Flagler is in the process of hiring a dedicated Grants & Compliance Manager that will be responsible for organizing and submitting reporting requirements moving forward. In the meantime, preparing of reporting will be completed, reviewed and published by current accounting personnel based on a reporting schedule created upon review of the award documents and related standards. Name(s) of the contact person(s) responsible for corrective action: Stacey Matthews and Tiffany Moore Planned completion date for corrective action plan: March 23, 2023

View Audit 40194

Finding 42952 (2022-002)

Significant Deficiency 2022

Suwannee County District School Board

FL

Student Financial Aid Reporting Subrecipient Monitoring

In response to Federal Award Finding 2022-002, updates to the National Student Loan Data System (NSLDS) will occur monthly to reflect Federal Financial Aid enrollment status changes and include the following procedures: 1) Financial Aid Coo...

In response to Federal Award Finding 2022-002, updates to the National Student Loan Data System (NSLDS) will occur monthly to reflect Federal Financial Aid enrollment status changes and include the following procedures: 1) Financial Aid Coordinator will review enrollment roster on NSLDS monthly for accuracy, print and sign monthly report. a. A monthly enrollment report will be pulled and cross-referenced with NSLDS Certification Report by additional Student Services staff member. b. If student data is missing or incorrect, the Financial Aid Coordinator will contact NSLDS to address. Missing or incorrect data will be reported to the Student Services Coordinator and Director in writing. 2) Financial Aid Coordinator will identify due dates to ensure compliance for 15 day window for reporting and maintain a calendar noting load dates to ensure deadlines are met. 3) Financial Aid Coordinator will submit monthly report to Student Services Coordinator for review. 4) Instructors will receive additional training addressing submittal of timely withdrawal forms. 5) Student enrollment status change will be updated upon receipt of student withdrawal form. Copies of the withdrawal form and status change will be placed in student's financial file. 6) Student Services Coordinator will review withdrawal form and status change documentation for reporting accuracy and timeliness, sign and date copy of status change form. Data between FOCUS Postsecondary Student Data System and NSLDS will be compared to ensure accuracy. The procedures noted above will ensure timely updates and accuracy in the National Student Loan Data System. The Financial Aid Coordinator will finalize all edits.

View Audit 40244

Finding 42944 (2022-003)

Material Weakness 2022

Manchester Community Schools

MI

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2022-003 Contact Person Responsible for Corrective Action: Darla Cain Contact Person Number: 260-982-7518 Views of Responsible Official: We concur with the findings. COVID-19 Education Stabilization Fund: Manchester Community Schools has established new controls for the mentioned above findi...

FINDING 2022-003 Contact Person Responsible for Corrective Action: Darla Cain Contact Person Number: 260-982-7518 Views of Responsible Official: We concur with the findings. COVID-19 Education Stabilization Fund: Manchester Community Schools has established new controls for the mentioned above finding. The assistant business manager will prepare and print the reports. The treasurer will review the financial reports for accuracy. The treasurer will sign off on accurate documents and will file the paperwork for future reference. Anticipated Completion Date: The new internal controls will begin February 2023 and continue according to the grant schedule.

View Audit 39147

Finding 42937 (2022-001)

None 2022

Yeshiva University

NY

Student Financial Aid Subrecipient Monitoring Reporting

Management Views and Corrective Action Plans 2022-001- Reporting on the Fiscal Operations Report and Application to Participate ("FISAP") Point of Contact- Robert Friedman, Director of Student Finance, (646-592-6255) Management agrees with the current year finding, which is related to the prior ye...

Management Views and Corrective Action Plans 2022-001- Reporting on the Fiscal Operations Report and Application to Participate ("FISAP") Point of Contact- Robert Friedman, Director of Student Finance, (646-592-6255) Management agrees with the current year finding, which is related to the prior year finding, and the recommendations to enhance controls to include a reconciliation process, to ensure completeness and accuracy of the FISAP. In addition, management will process a request to make the necessary corrections through the COD website and follow the procedures for submitting changes onto the FISAP. The University's Controller's Office or its designee in conjunction with the Office of Student Finance will perform a review of the FISAP reconciliation prior to filing. We believe this finding will be rernediated prior to the University filing the September 2023 FISAP after completing a full reconciliation of the Perkins fund and through collaboration with the Perkins Portfolio office.

View Audit 38914

Finding 42926 (2022-004)

Material Weakness 2022

Independent School District No. 548

MN

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness

Finding 2022-004 Special Tests and Provisions Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: In our testing of special tests and provisions for Prevailing Wage Requirements, it was identified that the District did not satisfy the requirements of 2 C...

Finding 2022-004 Special Tests and Provisions Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: In our testing of special tests and provisions for Prevailing Wage Requirements, it was identified that the District did not satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The district did not ensure proper inclusion of prevailing wage rate clauses were included in a construction contract and also did not obtain proper support to ensure required certified payrolls were submitted. Responsible Individuals: Brian Korf, Superintendent. Corrective Action Plan: The District will establish controls to follow all applicable requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: June 30, 2023

View Audit 39793

Finding 42924 (2022-001)

Material Weakness 2022

Noble Academy Cleveland

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding Number: 2022-001 Planned Corrective Action: See Below Anticipated Completion Date: 03/17/2023 Responsible Contact Person: Ramazan Celep, Treasurer The District is aware of the requirement in Federal program legislation to ensure inclusion of the prevailing wage rate provision in Agreeme...

Finding Number: 2022-001 Planned Corrective Action: See Below Anticipated Completion Date: 03/17/2023 Responsible Contact Person: Ramazan Celep, Treasurer The District is aware of the requirement in Federal program legislation to ensure inclusion of the prevailing wage rate provision in Agreements, as well as to obtain certified payroll reports to verify prevailing wages were paid. In the future, the District will work more closely with the contractor to ensure proper language is included in the bid documents and the contracts to ensure the District is in compliance with applicable federal regulations.

View Audit 39589

Finding 42922 (2022-001)

None 2022

Case Western Reserve University

OH

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles § 200.208 § 200.305

Management?s View and Corrective Action Plan Finding 2022-001 ? Cash Management Cluster: Research and Development Cluster Grantor: National Cancer Institute and National Science Foundation Assistance Listing #: 93.397, Cancer Centers Support Grants and 47.049, Mathematical and Physical Scienc...

Management?s View and Corrective Action Plan Finding 2022-001 ? Cash Management Cluster: Research and Development Cluster Grantor: National Cancer Institute and National Science Foundation Assistance Listing #: 93.397, Cancer Centers Support Grants and 47.049, Mathematical and Physical Sciences Title: Case GI SPORE, Case Comprehensive Cancer Support Grant, MRI: Acquisition of an SEM instrumented to conduct in-operando observations of materials performance under external stimuli Award Year and Number: 08/21/21-07/31/22 (CA150964), 04/01/21-03/31/22 (CA043703), 08/01/20-07/31/23 (DMR-2018167) The University believes it is in compliance and currently follows regulations pertinent to cash management in 2 CFR Part 200.305(b) (Uniform Guidance) which requires "payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity." As such, organizations are to minimize the time difference between vendor payment and requesting reimbursement from the sponsoring agencies. We acknowledge that there are discrepancies in the interpretation of the Office of Management and Budget (0MB) cash management compliance requirements and the Uniform Guidance Part 200.305(b). In October 2017, the Council on Governmental Relations (COGR) sent a letter to the Office of Federal Financial Management (OFFM) expressing concerns that the cash management requirement language in the 2017 Compliance Supplement was not aligned with the requirements for cash management included in the Uniform Guidance Part 200.305(b). COGR's stance is for the Compliance Supplement to be updated to correspond with the cash management requirements as written in the Uniform Guidance Part 200.305(b). In August 2021, COGR sent a follow-up letter to OFFM regarding the 2021 Compliance Supplement emphasizing the inconsistency has yet to be addressed or resolved and most recently followed-up again in June 2022. In September 2022, The Office of Research Administration (ORA) sent a letter in support of COGR's June 2022 Comment Letter and followed up in November 2022 as well, with no response. The Office of Research Administration is sincerely devoted to ensuring institutional compliance with Uniform Guidance and the Compliance Supplement. It is important to note that these exceptions pertain to accounts payable transactions only. ORA will be cognizant of OMB's current interpretation of the Cash Management requirements and will continue to monitor for additional guidance regarding discrepancies in the Compliance Supplement. Primary responsibility for implementing this corrective action plan for this finding rests with Diane Domanovics, Assistant Vice President for Sponsored Projects. Sincerely, Joan Schenkel Associate Vice President for Research

View Audit 39481

Finding 42914 (2022-002)

Material Weakness 2022

Hegg Memorial Hospital D/b/a Hegg Health Center

IA

Reporting Material Weakness Matching / Level of Effort / Earmarking

Finding 2022-002 Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Communities Facilities Loans and Grants Cluster Finding Summary: The Center does not have an internal control system designed to provide for the preparation of the schedule of expenditures of federal awards...

Finding 2022-002 Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Communities Facilities Loans and Grants Cluster Finding Summary: The Center does not have an internal control system designed to provide for the preparation of the schedule of expenditures of federal awards. As auditors, we were requested to assist with the preparation of the schedule of expenditures of federal awards. Responsible Individual: Bill Slater, Chief Financial Officer Corrective Action Plan: It is not cost effective to have an internal control system designed to prepare the schedule of expenditures of federal awards. We requested that our auditors, Eide Bailly LLP, to assist with the preparation of the schedule of expenditures of federal awards. We have designated a member of management to review the drafted schedule of expenditures of federal awards, and we have reviewed with and agree with the final schedule of expenditures of federal awards. Anticipated Completion Date: Ongoing

View Audit 39421

Finding 42913 (2022-003)

Material Weakness 2022

Hegg Memorial Hospital D/b/a Hegg Health Center

IA

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.303

Finding 2022-003 Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Communities Facilities Loans and Grants Cluster Finding Summary: The Center?s fiscal year 2023 operating budget was not submitted during the period under audit and prior year audited financial statements we...

Finding 2022-003 Department of Agriculture Federal Financial Assistance Listing/CFDA #10.766 Communities Facilities Loans and Grants Cluster Finding Summary: The Center?s fiscal year 2023 operating budget was not submitted during the period under audit and prior year audited financial statements were not submitted to USDA until USDA requested them, which was subsequent to the submission timeframe. Responsible Individual: Bill Slater, Chief Financial Officer Corrective Action Plan: A copy of the budget will be sent to USDA as soon as it is approved by the board and has been added to the year end procedures checklist. The audited financial statements will be provided to USDA upon finalization and within the 150 days of year end. Anticipated Completion Date: December 31, 2022

View Audit 39421

Finding 42911 (2022-003)

Material Weakness 2022

Shiloh Neighborhood Development Corporation

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.326

FINDING 2022-003: Prevailing Wage Rate Internal Control and Compliance Response: The District will notify contractors paid with federal funds of the prevailing wage requirement and require submission of weekly certified payrolls, prior to final payment.

View Audit 52114

Finding 42909 (2022-008)

Significant Deficiency 2022

South Carolina State University

SC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Finding 2022-008 Corrective Action Plan: In our effort to enhance our ability to access older Perkins Loan records, we will engage our information technology consultants to research our information collection system. Currently our ability to access older Perkins Loan records is restricted due to s...

Finding 2022-008 Corrective Action Plan: In our effort to enhance our ability to access older Perkins Loan records, we will engage our information technology consultants to research our information collection system. Currently our ability to access older Perkins Loan records is restricted due to system constraints. The findings from this engagement will be recorded and memorialized for the record. Anticipated Completion Date: June 30, 2023

View Audit 51591

Finding 42903 (2022-004)

Significant Deficiency 2022

South Carolina State University

SC

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding 2022-004 Corrective Action Plan: The Financial Aid division has revised its compliance process to ensure the effective administrative and internal control oversight of the notification of the Direct Loan disbursements. As a part of this revised compliance process, students receiving financi...

Finding 2022-004 Corrective Action Plan: The Financial Aid division has revised its compliance process to ensure the effective administrative and internal control oversight of the notification of the Direct Loan disbursements. As a part of this revised compliance process, students receiving financial aid while attending one or more other institutions will be ?singled out? for a detail review in accordance with the National Student Loan Data System (?NSLDS?) Student Transfer Monitoring Process. The Director of Financial Aid will perform periodic reviews to ensure the new process is being effectively executed in a timely and accurate manner. An internal review will be performed Spring 2023 with the Director of Financial Aid, Data Coordinator and neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb). Anticipated Completion Date: June 30, 2023

View Audit 51591

Finding 42896 (2022-007)

Significant Deficiency 2022

South Carolina State University

SC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Finding 2022-007 Corrective Action Plan: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination wi...

Finding 2022-007 Corrective Action Plan: To enhance the internal controls over the applicable compliance requirements of the enrollment reporting requirement to ensure that all status changes are submitted to the NSLDS website within the required timeframe, the Registrar?s office in coordination with the Information Technology Division will develop a ?flag based? process to capture and review all enrollment status changes on a monthly basis. This new reporting process will enhance the Registrar?s ability to review and accurately submit timely notifications to the National Student Loan Data System (?NSLDS?). These monthly reviews will be recorded and memorialized for the record. Anticipated Completion Date: June 30, 2023

View Audit 51591

Finding 42895 (2022-003)

Significant Deficiency 2022

South Carolina State University

SC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Finding 2022-003 Corrective Action Plan: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the ...

Finding 2022-003 Corrective Action Plan: The University has made the necessary changes to the staff and to the review process including, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University?s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeat finding, the University?s corrective action plan is being implemented immediately?Spring 2023. An internal review will be performed using Spring 2023 data with the assistance of the Director of Financial Aid, Director of Transfer Students and a neutral third party selected from another division within the University (documentation of these compliance tests will be memorialized for the record, June, Oct, Feb). Anticipated Completion Date: June 30, 2023

View Audit 51591

Finding 42884 (2022-004)

Significant Deficiency 2022

St. Luke's Hospital

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding 2022-004 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Finding Summary: One of the Hospital?s required reserve accounts was underfunded by approximately $45,000. Responsible Individuals: Jody Nelson, ...

Finding 2022-004 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Finding Summary: One of the Hospital?s required reserve accounts was underfunded by approximately $45,000. Responsible Individuals: Jody Nelson, CEO and Megan Peterson, CFO Corrective Action Plan: Proper tracking of all reserve accounts will be put in place in order to make sure they are all properly funded throughout the year. Anticipated Completion Date: 6/30/2023

View Audit 48518

Finding 42881 (2022-003)

Material Weakness 2022

St. Luke's Hospital

ND

Reporting Material Weakness Matching / Level of Effort / Earmarking

Finding 2022-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Federal Agency Name: Department of Health and Human Services Program Names: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distribut...

Finding 2022-003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants Federal Assistance Listing #10.766 Federal Agency Name: Department of Health and Human Services Program Names: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distribution; COVID-19 Coronavirus State Hospital Improvement Program Federal Assistance Listings #93.498 & 93.301 Finding Summary: Eide Bailly assisted in the preparation of our draft schedule of expenditures and federal awards and accompanying notes to the consolidated schedule of expenditures and federal awards. Responsible Individuals: Jody Nelson, CEO and Megan Peterson, CFO Corrective Action Plan: It is not cost effective to have an internal control system designed to provide for a complete and accurate schedule of expenditures and federal awards. We requested that our auditors, Eide Bailly LLP, assist in the preparation of the schedule of expenditures. We have designated a member of management to review the drafted schedule of expenditures. Anticipated Completion Date: Ongoing

View Audit 48518

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