Corrective Action Plans

Finding 553477 (2024-002)

Significant Deficiency 2024

Paine College

GA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Sup...

"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024 Criteria – Federal regulations governing Title IV programs. Condition – Non-compliances were noted, as more fully described in the context below. Questioned Costs – N/A Context – We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs 1) Three (3) out of 25 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). Cause – Oversight by responsible employees. Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable. Repeat Finding – No Auditor’s Recommendation – We strongly recommend the College refine the processes and procedures for the timely recording of disbursements in the general ledger allowing for more accuracy in financial reporting. View of Responsible Officials – The College has refined processes and procedures to ensure student refunds are processed within 14 days after the credit appears on the student account.

View Audit 352163

Finding 553475 (2024-001)

Significant Deficiency 2024

Miles City Eagles Manor

MT

HUD Housing Programs Matching / Level of Effort / Earmarking

Underpayment of the Flex Subsidy Loan On June 1, 2020, the Organization reached out to HUD with a plan to resolve the delinquent payments. Suggestions were to either forgive the loan or to have the payments be made from surplus cash. The Organization has not received correspondence concerning these ...

Underpayment of the Flex Subsidy Loan On June 1, 2020, the Organization reached out to HUD with a plan to resolve the delinquent payments. Suggestions were to either forgive the loan or to have the payments be made from surplus cash. The Organization has not received correspondence concerning these suggestions as of the date on this report, November 25, 2024. Karen Burkett, the Managing Agent, will work with the Organization to resolve this matter. The anticipated completion date is June 30, 2025.

View Audit 352155

Finding 553472 (2024-014)

Significant Deficiency 2024

The Howard University

DC

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

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet t...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet the cost share obligations and requirements. Anticipated Completion Date: December 31, 2025

View Audit 352153

Finding 551549 (2024-008)

Significant Deficiency 2024

The Howard University

DC

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

Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financi...

Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: Howard University uses automated processes to identify and send loan disbursement notifications to parents and students. The nightly UC4 process prompted Banner to send out a Direct Loan notification to the student and/or parent. This UC4 process showed all students who had a Direct Loan disbursement after the last nightly UC4 process was run. During a compliance review of disbursement notifications during the Fall 2023 semester and the Loans Team worked with Banner consultants to determine the reason for this. While this issue was being reviewed and a solution created, the Loans Team used the RLRDLDD report in Banner, which is a report that showed all loans disbursed. This report could be matched against the UC4 listing of loans disbursed. This check between UC4 and the RLRDLDD report was used to send out loan notifications that was missed during the UC4 process during the Fall 2023 semester. During a Spring 2024 compliance review of disbursement notifications, it was discovered the RLRDLDD report was missing disbursements as well. As a corrective action, the Loans Team then began using a loan audit report out of the Argos reporting system to identify students who may have a disbursement not included in the UC4 and/or RLRDLDD report. The support time required for maintenance of Banner was also reduced due to the ongoing integration and implementation efforts to prepare Workday for the Fall 2024 semester. This increased the length of time it took to correct the UC4 process and RLRDLDD reports. Howard no longer uses Banner to send out Graduate PLUS, Subsidized and Unsubsidized loan notifications. Workday now is now responsible for sending out the disbursement notification after a loan has disbursed and there is a record in the student’s Activity History to document the loan notification has been sent. Parent PLUS Loan notifications must be sent out manually due to Workday not having the capability to send a disbursement notification to the parent’s email on file. The “FA CR Parent PLUS Disbursement Notification Report” is run weekly out of Workday to identify all Parent Plus Loan disbursements and a notification is sent to the parent’s email address on file. Bi-semester reviews are completed by the Associate Director for Compliance to ensure the loan disbursement notifications are being sent to students and parent in the required 30-day timeline. These reviews also ensure inclusion in the loan notification of all federally required information. Anticipated Completion Date: This corrective action plan was completed during Fall 2024 implementation of Workday. Monitoring and reviewing of loan disbursements has been ongoing to ensure the Workday system is correctly identifying and transmitting Direct Loan disbursements. Given that Workday is a new ERP, Howard recognizes maintenance and review of the disbursement notification process will be ongoing.

View Audit 352153

Finding 551543 (2024-003)

Significant Deficiency 2024

The Howard University

DC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Oliver Street, Interim University Registrar; Saleem Sullivan, Associate Registrar for Compliance; La Estes, Records Specialist; Ben Carmichael, Associate Director for Compliance, Enrollment Reporting; Sarah Mariner, Assistant Director for Compliance, Financial Aid Co...

Name of Responsible Individual: Oliver Street, Interim University Registrar; Saleem Sullivan, Associate Registrar for Compliance; La Estes, Records Specialist; Ben Carmichael, Associate Director for Compliance, Enrollment Reporting; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP). Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future. Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date. Anticipated Completion Date: The correction to the length of each program in Workday was implemented during setup prior to the start of the Fall 2024 semester. There will be a Spring 2025 review performed by the Associate Director for Compliance to ensure the program length is accurately reported and testing shows this issue to be resolved. Each semester, enrollment reporting samples will be selected (approximately) 2 to 3 weeks after the first enrollment file for the semester is sent to NSC. Howard has set up a transmittal calendar with NSC which determines when enrollment files, including the graduate files, are transmitted. Due to work completed regarding the integration of Workday with NSC, Howard worked closely with NSC during Fall 2024 to troubleshoot issues that could delay enrollment files transmission. The schedule for submission of files was setup during this time. Howard currently has a vacancy at the University Registrar position and experienced individuals with Workday user knowledge will be pursued for hire. The hiring date for the University Registrar has not been approximated due to the positional requirement of Workday experience and the newness of the ERP system into the higher education space. The current Interim Registrar has prior University Registrar experience with knowledge of the requirements to be effective in the position.

View Audit 352153

Finding 551540 (2024-005)

Significant Deficiency 2024

The Howard University

DC

Internal Control / Segregation of Duties Student Financial Aid Matching / Level of Effort / Earmarking

Name of Responsible Individual: Keith Anderson, Associate Provost, Office of Undergraduate Studies; Paapa Berko, Federal Work-Study Coordinator; Tina Knight, Director, Center for Career & Professional Success; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Dani Hollis, Ass...

Name of Responsible Individual: Keith Anderson, Associate Provost, Office of Undergraduate Studies; Paapa Berko, Federal Work-Study Coordinator; Tina Knight, Director, Center for Career & Professional Success; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Dani Hollis, Associate Director of Operations & Customer Service; John Hooth, Senior Director of Payroll; Sasha Quinga, Senior Director, Human Resources Information Systems Corrective Action: Federal Work Study (FWS) supervisors are required to have training on the appropriate policies and procedures when hiring a FWS student. They sign off on the Federal Work Study supervisor agreement stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours, as this is a not a best practice. The Center for Career & Professional Success began using this updated FWS supervisor agreement beginning with the Spring 2025 semester. All FWS supervisors who had students for Fall 2024 were required to review and sign the updated agreement as well. The Federal Work Study Coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works. The Federal Work Study Coordinator also ensures supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. The full-time Federal Work Study Coordinator position was filled prior to the end of the Fall 2024 semester, and this ensures a full-time employee is now in place to help provide a more active review of the Federal Work Study program. One student was not paid FWS earnings within 30 days. At the time, Howard University did not print out paper checks, only providing FWS payments as a direct deposit. The student was to be paid for those two pay periods (10/8/23-10/21/23 and 10/22/23-11/4/23) on 11/3/23 and 11/17/23. The student did not have any payment selections set up in the system for the earnings to be deposited into and this delayed the receipt of the Federal Work Study payment. Working with the AVP for Enrollment Management, we have discussed with Payroll the need to process a paper check if a student chooses this delivery method. The University is also working on an awareness campaign that will encourage students to set up their direct deposit information in Workday. Students understanding the need to set up direct deposit and the willingness to process paper checks, if necessary, should prevent this finding from recurring. The Associate Director for Compliance or designee will review when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working during class hours. These reviews of FWS hours matching the students’ earnings will provide another layer of oversight. Anticipated Completion Date: The Center for Career and Professional Services hired a full-time Federal Work Study Coordinator towards the end of the Fall 2024 semester. All FWS supervisor training occurs prior to the hire of any FWS students, and the supervisor agreement has been updated as of December 2024 to reflect supervisors signing they understand students are not to have time approved prior to working those hours. The awareness campaign encouraging students to choose the direct deposit option in Workday will begin in late Spring as the Fall 2025 class prepares to enter Howard.

View Audit 352153

Finding 551538 (2024-007)

Significant Deficiency 2024

The Howard University

DC

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

Name of Responsible Individual: Carmela Goodall, Manager, Systems and Administration (Office of the Bursar); Robin Whitfield, Associate Vice President for Finance & Bursar; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Linda Coles, Director of Cash Management, Treasury Op...

Name of Responsible Individual: Carmela Goodall, Manager, Systems and Administration (Office of the Bursar); Robin Whitfield, Associate Vice President for Finance & Bursar; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Linda Coles, Director of Cash Management, Treasury Operations; Keynesha Wilson, Treasury Specialist; Kathleen Harrod, Accounts Payable Disbursement Manager; Rawle Howard, Assistant Vice President, Procurement Corrective Action: There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023. The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester. Anticipated Completion Date: Howard feels this finding has been mitigated and there will be no further findings where students received a Title IV credit balance check past the 14-day deadline. Semester or bi-semester reviews will be completed by Financial Aid to ensure the University is sufficiently meeting the federal requirements for students and/or parents to receive the Title IV credit balance check within 14 days.

View Audit 352153

Finding 551537 (2024-006)

Significant Deficiency 2024

The Howard University

DC

Student Financial Aid Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Sarah Mariner, Assistant Director for Compliance, Financial Aid; Robin Whitfield, Associate VP for Finance & Bursar; Guillermo Creamer, Collections Manager; Robert Muhammad, Executive Director o...

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Sarah Mariner, Assistant Director for Compliance, Financial Aid; Robin Whitfield, Associate VP for Finance & Bursar; Guillermo Creamer, Collections Manager; Robert Muhammad, Executive Director of Financial Aid; Brenda Willis, Senior Executive Director of Financial Grants & Contracts; Educational Computer Systems, Inc. Corrective Action: Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University. Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31. Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity. It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP. The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15. Anticipated Completion Date: Summer 2025 is the date the University anticipates having liquidated the Perkins program. Cash on Hand will be reported as of June 30 and updated again on October 31. Completion of the FISAP is due September 30, 2025 and final edits to the FISAP are due December 15, 2025. Howard will update the Cash on Hand and tuition and fees as of December 15, 2025 for final submission. The U.S. Department of Education will then review the submitted FISAP for errors or inconsistencies. Should there be no errors or inconsistencies from ED’s review, they will accept the FISAP and begin basing any Excess Liquid Capital return request on the Cash on Hand reported.

View Audit 352153

Finding 551531 (2024-001)

Significant Deficiency 2024

Alameda Health Consortium

CA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

The audit was filed late in 2023 due to an extended vacancy of a key finance position combined with the selection of a new audit firm, which resulted in additional time to prepare for and complete the audit. It is expected that this should not be an issue going forward.

View Audit 352145

Finding 551518 (2024-002)

Significant Deficiency 2024

Lemoyne-Owen College

TN

Questioned Costs Student Financial Aid Significant Deficiency

Finding 2024-002 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Per 34 CFR 68...

Finding 2024-002 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (Significant Deficiency): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1. Per 34 CFR 685.300(b)(5), the College provided reconciliations for the following programs, however the reconciliations were not correct and therefore the programs were not properly reconciled, monthly or annually. a. Federal Pell Grant Program b. Federal Direct Loan Program c. Federal FSEOG Program d. Federal Work Study Program 2. The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for the Federal Pell Grant Program. 3. The College distributed the Annual Security and Fire Report (ASR) on October 10th, 2024. PER 34 CFR 668.41, By October 1 of each year, an institution must distribute the ASR to all enrolled students and current employees as described in § 668.46(b). 4. Per HEA, Section 484B and 34 CFR 668.22, one (1) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement that the college determined the student withdrew. 5. Per HEA, Section 484B & 34 CFR 668.22, three (3) out of 6 students tested for withdrawals and the return of Title IV funds did not have their Title IV program post-withdrawal disbursement funds disbursed within the 45-day requirement that the college determined the student withdrew. 6. Per HEA, Section 484B & 34 CFR 668.22, five (5) out of 6 students tested for withdrawals and the return of Title IV funds (R2T4) and the school did not complete the R2T4 calculations correctly. As a result of these inaccuracies, two (2) students were overpaid Pell and Direct Loan (DL) funds in the amount of $612 and one (1) student was underpaid $866 in Pell funds. The following errors occurred: a. Incorrect withdrawal dates were used b. Incorrect dates of determination were used c. Funds that could have been disbursed were incorrectly recorded as funds disbursed The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – Title IV reconciliations were prepared. They have been provided to WPG. The College hired an experienced Director of Financial Aid on February 18, 2025. She will ensure the proper reconciliation and management of all financial aid programs and the accurate and timely submission of program reports. The Director of Campus Security has been advised of the deadline for distribution of the Annual Security and Fire Report (ASR).

View Audit 352118 Questioned Costs: $1

Finding 551510 (2024-002)

Significant Deficiency 2024

Homeless Assistance Leadership Organization, Inc.

WI

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.302

Action in response to finding: The Organization will either add internal resources to address the matters noted in the finding or outsource its accounting function to a third party with these capabilities. Name of the contact person responsible for corrective action: Yvonne MacDonald Hames Planned c...

Action in response to finding: The Organization will either add internal resources to address the matters noted in the finding or outsource its accounting function to a third party with these capabilities. Name of the contact person responsible for corrective action: Yvonne MacDonald Hames Planned completion date for corrective action plan: June 30, 2025

View Audit 352116

Finding 551508 (2024-001)

None 2024

Valor Christian College

OH

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

FINDING 2024-001: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOANS- the auditor tested forty files, thirty-six of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. It is recommended the College reclassify $2,124 from uns...

FINDING 2024-001: UNDERAWARDED FEDERAL DIRECT SUBSIDIZED LOANS- the auditor tested forty files, thirty-six of which were Federal Direct Loan recipients, and two students did not receive the full amount of their Federal Direct Subsidized Loans. It is recommended the College reclassify $2,124 from unsubsidized to subsidized and increase controls over packaging direct loans. Comments on Finding and Recommendation(s): We concur with the finding and we believe that these account represent a unique situtation. Actions Taken or Planned: For A1, Valor was able to rectify the account because it was within the 180-day limit. We have implemented an internal audit process that takes place twice each semester to reconcile federal aid awarded with the appropriate aid based on enrollment status and grade level. For A-2, Value is unable to reallocate subsidized and unsubsidized awards for the second student as the 180-day limit has passed. The student was awarded the correct total amount of aid. Moving forward, Valor will generate an NSLDS report whenever a 258 ISIR code appears on the ISIR to ensure proper aid allocation.

View Audit 352114

Finding 551506 (2024-003)

Significant Deficiency 2024

Clarkson University

NY

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Management accepts this finding. The error on the verification (1 student) was made by a former staff that did not verify the student wages. Clarkson’s procedure clearly states the income is required to be verified, however the former staff member made an error in processing this verification. Impr...

Management accepts this finding. The error on the verification (1 student) was made by a former staff that did not verify the student wages. Clarkson’s procedure clearly states the income is required to be verified, however the former staff member made an error in processing this verification. Improvements to the training process have been implemented including emphasis on the requirement that staff verify income as part of the review process. A multi-tier review system has been implemented whereby after the initial review process has been completed, verification documents are submitted to the Director who then performs a second review to ensure that the initial review process was correctly followed and that the data is reliable. Anticipated Completion Date December 2024 - completed Responsible Person Nicole Adner, Director of Financial Aid

View Audit 352112

Finding 551505 (2024-002)

Material Weakness 2024

Clarkson University

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management accepts this finding and notes there were issues with the disbursement records that prevented them from being sent to COD. Unexpected turnover in the workforce resulted in 25% normal processing capacity during the timeframe in question. Staffing levels in that area have been fully restore...

Management accepts this finding and notes there were issues with the disbursement records that prevented them from being sent to COD. Unexpected turnover in the workforce resulted in 25% normal processing capacity during the timeframe in question. Staffing levels in that area have been fully restored with appropriate training to the employees. A formal schedule has been developed whereby records are reconciled and sent to COD on a weekly basis to reduce the risk of late filings. In addition, the University is considering methods of improved redundancy and backup to prevent systemic issues going forward. Anticipated Completion Date December 2024 - completed Responsible Person Nicole Adner, Director of Financial Aid

View Audit 352112

Finding 551503 (2024-005)

Significant Deficiency 2024

South Carolina State University

SC

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Student Financial Aid § 200.303

Corrective Action Plan The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken: 1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and ...

Corrective Action Plan The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken: 1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and internal controls related to the submission of origination and disbursement records to the COD system. This includes implementing stricter monitoring mechanisms to ensure all records are submitted within the required timeframes. 2. Implement Advanced Technology Solutions: To improve the efficiency and accuracy of financial reporting, the University will adopt advanced technology solutions. These tools will facilitate timely and accurate submission of required data to the COD system. The newly established internal audit team will oversee the implementation and management of these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal origination and disbursement requirements. By taking these steps, the University aims to rectify the identified deficiency and prevent future occurrences, thereby maintaining the integrity of its financial reporting processes. Anticipated Completion Date: September 1, 2025

View Audit 352110

Finding 551502 (2024-004)

Significant Deficiency 2024

South Carolina State University

SC

Questioned Costs Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal financial aid regulations. The following steps will be undertaken: 1. Strengthen Financial Aid Coordination: The Financial Aid team will enhance coo...

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal financial aid regulations. The following steps will be undertaken: 1. Strengthen Financial Aid Coordination: The Financial Aid team will enhance coordination among various programs and between federal and non-federal aid sources to ensure that total aid awarded does not exceed a student’s financial need or cost of attendance. This aligns with federal regulations requiring institutions to prevent over awards by adjusting aid packages accordingly. 2. Implement Advanced Technological Solutions: The University will collaborate with technology support teams to develop data platforms and scripts that monitor and control award amounts, ensuring they do not surpass students’ cost of attendance. This proactive approach will aid in preventing future over award situations. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal financial aid regulations and to uphold the integrity of its financial aid programs. By implementing these measures, the University aims to rectify the identified over award issue and prevent similar occurrences in the future, thereby maintaining compliance with Title IV funding requirements. Anticipated Completion Date: September 1, 2025

View Audit 352110 Questioned Costs: $1

Finding 551497 (2024-002)

Significant Deficiency 2024

South Carolina State University

SC

Student Financial Aid Special Tests & Provisions Procurement, Suspension & Debarment § 200.303

Corrective Action Plan The University acknowledges this finding and during its liquidation of the Federal Perkins Loan Program completed the buyback of certain loans for which the University was not able to provide adequate documentation to assign these loans to the Department of Education. Subse...

Corrective Action Plan The University acknowledges this finding and during its liquidation of the Federal Perkins Loan Program completed the buyback of certain loans for which the University was not able to provide adequate documentation to assign these loans to the Department of Education. Subsequent to June 30, 2024, the University has completed the following steps in the closeout of its Federal Perkins Loan Program: 1. Notified the Department of Education of the intent to liquidate. 2. Assigned outstanding Perkins loans to the Department of Education and updated NSLDS throughout the assignment process. 3. Purchased loans not qualifying for assignment and submitted cash on hand (Intent and Closeout Form Phase 3 in COD) 4. Remitted the federal share to the Department 5. Submitted final FISAP data (Intent to Closeout Form Phase 4 in COD) The final remaining step for the University to complete closeout of its Federal Perkins Loan Program is to submit a Perkins closeout audit to the Department. This will be submitted as part of the Single Audit for the year ended June 30, 2025, which is due March 31, 2026. Anticipated Completion Date: June 30, 2025

View Audit 352110

Finding 551494 (2024-003)

Significant Deficiency 2024

South Carolina State University

SC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid § 200.303

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The Univ...

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal regulations regarding the Return of Title IV Funds (R2T4). The following steps will be undertaken: 1. Establish an Internal Audit Function: The University has requested a position from the State of South Carolina Human Resources Office to create an internal auditor role. A dedicated budget line item is being developed to support this function, which will oversee all corrective action plans and serve as the primary contact for audit-related matters, providing onsite management for compliance issues within the University and its affiliated agencies. 2. Enhance Communication Between Departments: The Financial Aid team will strengthen coordination with the Registrar’s Office to ensure timely identification of student withdrawals. This collaboration is essential to initiate the process promptly and adhere to the required deadlines. 3. Implement Technological Solutions: The University will engage technical support to develop alert systems that notify relevant departments of impending compliance deadlines and requirements related to Title IV funds. This proactive approach will facilitate timely actions and reduce the risk of non-compliance. The internal audit team will oversee and manage these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal regulations governing the return of Title IV funds. By implementing these measures, the University aims to rectify the identified deficiency and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal requirements. Anticipated Completion Date: September 1, 2025

View Audit 352110

Finding 551493 (2024-001)

Significant Deficiency 2024

South Carolina State University

SC

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring § 200.303

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeki...

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies. 2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance. 3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing. 4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner. 5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance. The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements. By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations. Anticipated Completion Date: September 1, 2025

View Audit 352110

Finding 551444 (2024-006)

Significant Deficiency 2024

Volunteers of America Western Washington and Subsidiary

WA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.430

We acknowledge BDO’s recommendation to ensure consistent approval and retention of timesheets by both employees and supervisors for each pay period requested for reimbursement. However, VOAWW asserts that we have established controls in place to obtain and retain timesheet approvals, and the two ins...

We acknowledge BDO’s recommendation to ensure consistent approval and retention of timesheets by both employees and supervisors for each pay period requested for reimbursement. However, VOAWW asserts that we have established controls in place to obtain and retain timesheet approvals, and the two instances of missing approvals identified in the audit were due to human error rather than a lack of controls. To prevent such occurrences in the future and reinforce our existing procedures, we will continue implementing and strengthening the following controls: • Proactive Timesheet Approval Monitoring – Reports are regularly run to identify missing timesheet approvals before payroll is processed. Employees and supervisors with outstanding approvals receive reminders to ensure further action as needed, including notifying program directors about missing timesheet submissions or approvals resulting in out-of-compliance with federal awards and Uniform Guidance. • Real-Time Payroll Processing Checks – During payroll processing, additional reminders are sent to employees and supervisors who have not yet approved their timesheets, further reducing the likelihood of omissions. • Additional Approval Outside the System – In response to BDO’s recommendation, we will require managers to email Payroll at the end of every pay period affirming that they have reviewed and approved all timecards. This additional layer of approval ensures that even if a manager forgets to approve a timesheet in the system, there is still documented confirmation of their review. • Post-Payroll Compensating Control Implemented in FY24 – To mitigate any risk of over/undercharging grants due to miscoded time from unapproved timesheets, a compensating control was introduced in FY24. This process requires Program Management to review and approve a post-payroll report identifying any discrepancies in time allocations, ensuring that all time charged to grants is accurate and properly approved. • Documentation and Continuous Improvement – VOAWW provided attestations to BDO where available and acknowledges that the compensating control was not fully implemented during FY23 but was in place for most of FY24. Moving forward, we will ensure that this control is consistently applied across all programs. By maintaining and strengthening these controls, including the additional email approval process, we are confident in our ability to ensure proper timesheet approvals while mitigating any risk of inaccurate grant charging. Responsible Individual: Claire Danielson, Controller Estimated time of completion: June 2025

View Audit 352105

Finding 551422 (2024-005)

Significant Deficiency 2024

Volunteers of America Western Washington and Subsidiary

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Equipment & Real Property Management § 200.303 § 200.430 § 200.465

We acknowledge the auditors’ recommendation regarding the need for a more arm’s-length approach in determining rent charges between entities. To address this finding, we are making adjustments to our rent allocation methodology to enhance transparency and ensure compliance with best practices. As ...

We acknowledge the auditors’ recommendation regarding the need for a more arm’s-length approach in determining rent charges between entities. To address this finding, we are making adjustments to our rent allocation methodology to enhance transparency and ensure compliance with best practices. As part of our corrective action plan, we will implement the following measures: • Transition to an Actual Expense Allocation Methodology – VOAWW will modify the rent allocation process to allocate actual expenses incurred, ensuring that charges between entities reflect true costs. This approach eliminates the need for a year-end true-up process while maintaining fairness and accuracy. • Implementation of a True-Up Process for FY25 – While transitioning to the new methodology, we will conduct a true-up process for FY25 to reconcile any discrepancies and ensure that rent allocations align with actual expenses. These actions will help strengthen our internal controls and ensure that inter-entity rent allocations are handled in a compliant and equitable manner. Responsible Individual: Claire Danielson, Controller Estimated time of completion: June 2025

View Audit 352105

Finding 551394 (2024-001)

None 2024

St. Lukes Health Network, Inc. and Controlled Entities

PA

Questioned Costs Cash Management Matching / Level of Effort / Earmarking

2024-001 – Duplicate Invoices Submitted for Reimbursement Cluster: Community Facilities Loan and Grant Cluster Federal Granting Agency: Department of Agriculture Award Name: Rural Housing Service Assistance Listing #: 10.766 Assistance Listing Title: Community Facility Loans and Grants Award Year: J...

2024-001 – Duplicate Invoices Submitted for Reimbursement Cluster: Community Facilities Loan and Grant Cluster Federal Granting Agency: Department of Agriculture Award Name: Rural Housing Service Assistance Listing #: 10.766 Assistance Listing Title: Community Facility Loans and Grants Award Year: July 1, 2023 – June 30, 2024 The Network agrees with the finding, and will make the following enhancements to the process: The current process includes the following: 1. Accounts Payable produces a report for each project listing the invoices, vendor, and amounts. 2. The Vice President of Finance reviews the report and follows-up with Accounts Payable and/or the project manager. 3. Once the reports appear to be accurate, the Vice President of Finance creates subtotals on the file for Construction, FFE, Contingency. These are needed for the USDA Application form with balances remaining calculated. 4. The Administrative Assistant, Finance, prepares the USDA application form and obtains the signature of the Senior Vice President of Finance. 5. The Administrative Assistant, Finance, sends the Application and a copy of the invoices to the USDA Area Specialist for approval. 6. The Application is digitally signed by the Area Specialist, USDA Rural Development, and a copy is sent back to the Administrative Assistant, Finance, to maintain with our records. Enhanced Controls The Senior Financial Analyst will review the Application/Requisition and the individual invoices to verify they were eligible per the letter of conditions. Additionally, she will compare the invoices on the current requisition to the last two requisitions to verify there are no duplicate invoices. Both the Senior Financial Analyst and the Vice President of Finance will sign-off after their review to show evidence of review and approval. For inquiries regarding this finding, please contact Evelyn Diaz, Senior Financial Analyst, and Carl Alberto, Vice President of Finance, who are responsible for the corrective action. Sincerely, Dean Silfies AVP, Financial Accounting & Reporting Services

View Audit 352093 Questioned Costs: $1

Finding 551393 (2024-005)

Material Weakness 2024

Hampton University

VA

Eligibility Reporting Matching / Level of Effort / Earmarking

Management agrees with this finding. The SSS director and staff will review the key line-item data at the point of entry to ensure the completeness and accuracy of information input into the Blumen system. Training will also be provided for the new administrative assistant. Prior to submitting the A...

Management agrees with this finding. The SSS director and staff will review the key line-item data at the point of entry to ensure the completeness and accuracy of information input into the Blumen system. Training will also be provided for the new administrative assistant. Prior to submitting the APR, a download of all data categories will be reviewed for accuracy and completeness.

View Audit 352091

Finding 551391 (2024-004)

Material Weakness 2024

Hampton University

VA

Student Financial Aid Special Tests & Provisions Reporting

The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors within Banner, so we do not have these concerns in the future. The Architect students mapping issue was corrected by the Registrar Office in March 2025. The Registrar’s ...

The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors within Banner, so we do not have these concerns in the future. The Architect students mapping issue was corrected by the Registrar Office in March 2025. The Registrar’s Office has created a new program code that will reflect next semester’s registrations and updated previous majors.

View Audit 352091

Finding 551223 (2024-001)

None 2024

Temple University

PA

Questioned Costs Equipment & Real Property Management HUD Housing Programs § 200.313

Corrective Action Plan: Temple concurs with the finding and has contacted the specified sponsors to obtain specific required documentation on transferred equipment and request retroactive disposition instructions. To improve compliance, Temple will update its equipment management policy to include p...

Corrective Action Plan: Temple concurs with the finding and has contacted the specified sponsors to obtain specific required documentation on transferred equipment and request retroactive disposition instructions. To improve compliance, Temple will update its equipment management policy to include procedures for equipment transfers between institutions. Equipment transfers will also be added to the internal PI transfer checklist. Additionally, we will enhance the training program for equipment managers to cover equipment transfer procedures. Action Date: March 24, 2025 Final Implementation Date: May 31, 2025 Name And Phone Number of Person Responsible for Implementation: Josh Gladden, (215) 204-370- 8138 See " Corrective Plan" on pages 127-128

View Audit 352087 Questioned Costs: $1

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