Corrective Action Plans

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Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following co...
Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following corrective actions: 1. Required Agency Acknowledgment at Delivery Management will reinforce procedures requiring recipient agency signatures or equivalent acknowledgment on all USDA food distribution invoices at the time of delivery. Distribution staff and drivers will be reminded that unsigned delivery documentation is considered incomplete. 2. Post-Delivery Follow-Up Control Management will implement a follow-up control, such as a delivery log or checklist, to track all USDA distributions recorded at the time of delivery. The log will include verification that a signed receipt has been obtained and returned for each transaction. 3. Reconciliation of Distributions to Signed Documentation On a periodic basis, management will reconcile USDA distribution activity to signed agency invoices to identify any missing acknowledgments. Missing signatures will be promptly investigated and resolved, with documentation of follow-up retained. 4. Supervisory Review and Oversight Supervisory personnel will perform periodic documented reviews of distribution documentation to verify that signed agency receipts are obtained, complete, and retained. Evidence of review will be maintained. 5. Training and Awareness Management will provide refresher training to distribution staff and drivers on USDA documentation requirements and the importance of obtaining signed acknowledgment to support program accountability and reporting accuracy. Expected Completion Date: Within 60-90 days Responsible Parties: Andrelle Bowen, Transportation Manager, (901-373-0402)
Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as ...
Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as an attachment. The required Progress Report was filed timely and accepted by HUD, however the required Federal Financial Report was omitted from the submission. Recommendation: The entity should implement and document internal controls to ensure all required reports are prepared, reviewed, and submitted in accordance with federal award requirements. Action Taken: To address the root cause and ensure strict adherence to federal reporting standards moving forward, the Finance Department has implemented the following internal controls, effective immediately: 1. Implementation of a Pre-Submission Checklist: A mandatory "Federal Reporting Checklist" has been developed. This document requires the preparer to physically check off that all required attachments—including narrative progress reports and financial reports (SF-425)—are present and accurate prior to upload. 2. Staff Training: Relevant staff members involved in the grant reporting process have been retrained on the specific submission requirements for HUD awards to ensure clarity on all deliverable components. Responsible Official: Rambod Behnam, Director of Finance Planned Completion Date: June 30, 2026.
The City concurs with the finding. Audit testing identified no reporting errors, no noncompliance, and no questions costs; however, the City acknowledges that documentation of independent supervisory review was not formally required or retained prior to submission of federal reports and reimbursemen...
The City concurs with the finding. Audit testing identified no reporting errors, no noncompliance, and no questions costs; however, the City acknowledges that documentation of independent supervisory review was not formally required or retained prior to submission of federal reports and reimbursement requests. To strengthen documentation of internal control over compliance, the City will implement a formalized and documented secondary review process for all federal financial reports, performance reports, and reimbursement requests, to be retained in grant files in accordance with CFR §200.334 record retention requirements.
Corrective Action Plan Description: Effective October 2025, FH will strengthen its documentation controls to ensure that only the final, approved version of each timesheet is maintained as support for payroll charges to federal awards. Any timesheet revised during the review and approval process wil...
Corrective Action Plan Description: Effective October 2025, FH will strengthen its documentation controls to ensure that only the final, approved version of each timesheet is maintained as support for payroll charges to federal awards. Any timesheet revised during the review and approval process will be clearly marked as “void,” and removed from the official support file. Payroll and grant personnel will be instructed on this updated procedure to ensure compliance with 2 CFR 200 documentation standards. FH will perform periodic reviews to confirm consistent application of the revised process. Responsible: GSC Grants Finance Officer Due Date: 02/28/2026
Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and no...
Finding 2025-002 - Eligibility - Student Financial Assistance Cluster, ALN 84.268, June 30, 2025 Award Year, U.S. Department of Education Condition Calculation of Benefits: In addition to the requirements and limits, awards must be coordinated among the various programs and with other federal and nonfederal aid (need and non-need-based aid) to ensure that total aid is not awarded in excess of the student’s financial need or cost of attendance (34 CFR 668.42, FWS, and FSEOG, 34 CFR 673.5 and 673.6; Direct Loan, 34 CFR 685.301). The determination of need-based SFA award amounts is based on financial need. Non-need based SFA awards are not limited to financial need but cannot exceed the student’s COA. To determine non-need based SFA awards (unsubsidized aid) one would use the following formula – COA minus OFA. (November 2025 OMB Compliance Supplement pages 5-3-10 and 5-3-11) Out of forty students tested, two students were under-awarded both Subsidized and Unsubsidized loans and one student was under-awarded Subsidized loans. This was not a statistic. Corrective Actions To address the finding, loan certification procedures have been revised to include step-by-step procedures for determining loan eligibility. A standardized template has been created for calculating subsidized and unsubsidized loan amounts, with clear instructions that subsidized loans must be maximized before awarding unsubsidized loans. Comprehensive training on the calculation of loan eligibility has been provided for new staff, including subsidized versus unsubsidized loan rules, and one-on-one coaching is being provided for staff members with knowledge gaps. A quality assurance program that includes a random sample review of loan awards will be performed between the fall and winter semesters to identify errors and ensure that loans are being certified in accordance with applicable rules and limits. Reviews and findings will be documented so that errors can be addressed immediately. Responsible Official: Wendy G. Glass, Director of Student Financial Services Completion Date: December 4, 2025
Matching – Assistance Listing No. 93.671 Recommendation: We recommend the Organization enhance its internal controls over the review of the payroll allocation to ensure matching contributions are accurately calculated and supported. Explanation of disagreement with audit finding: There is no disagre...
Matching – Assistance Listing No. 93.671 Recommendation: We recommend the Organization enhance its internal controls over the review of the payroll allocation to ensure matching contributions are accurately calculated and supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Senior Accountant or Director of Grants and Compliance will conduct the initial review to ensure that match costs are allowable, properly supported, and accurately calculated. The Chief Financial Officer will perform a secondary review and approval to validate completion of the initial review and confirm that reported match amounts reconcile to supporting documentation. Evidence of review will be documented through dated signatures or electronic approval within the grant billing file. Name of the contact person responsible for corrective action: Ashley Freivogel Planned completion date for corrective action plan: September 30, 2026
Management engaged an external HR consultant to assist with revising the Accounting Policy Manual to formally document written policies and procedures related to compensation and fringe benefits. Draft policies have been developed and are currently under management review for accuracy and alignment ...
Management engaged an external HR consultant to assist with revising the Accounting Policy Manual to formally document written policies and procedures related to compensation and fringe benefits. Draft policies have been developed and are currently under management review for accuracy and alignment with existing practices. The finalized policies will be presented for Board approval and implemented by March 18, 2026, and responsibility for ongoing monitoring and periodic review has been assigned to the Chief Financial Officer and Director of Administration to ensure continued compliance. Training will be provided to applicable staff, and compliance with the updated policies will be incorporated into management’s periodic internal reviews.
In order to maintain procedures to verify the disbursement dates in the COD System agree to the date funds are credited to the student’s account in the colleges Accounts Receivable subledger to the general ledger, the institute has updated its procedures. The Financial Aid Office will adjust the sch...
In order to maintain procedures to verify the disbursement dates in the COD System agree to the date funds are credited to the student’s account in the colleges Accounts Receivable subledger to the general ledger, the institute has updated its procedures. The Financial Aid Office will adjust the scheduled disbursement date according to updated procedures when disbursement occurs earlier than the scheduled date to ensure accuracy of reporting data to COD. These are updates to the current Disbursement Policy and Procedures.
The Chief Financial Officer will ensure staff retain documentation of the review and approval of grant reports prior to being submitted, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of the review and approval of grant reports prior to being submitted, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediatel...
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
FINDING 2025-002 Finding Subject: Education Stabilization Fund – Wage Rate Requirements Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: (765) 522-6218 / tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Desc...
FINDING 2025-002 Finding Subject: Education Stabilization Fund – Wage Rate Requirements Contact Person Responsible for Corrective Action: Tanya Pearson Contact Phone Number and Email Address: (765) 522-6218 / tpearson@nputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Although the Education Stabilization Fund projects have been completed, the School Corporation will implement procedures to ensure compliance with Davis Bacon and wage rate requirements for all future federally funded grants that have this stipulation. Anticipated Completion Date: Immediately (February 1, 2026)
2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan ...
2025-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing #s 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2025 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $586 in Subsidized Loans and $2,914 in Unsubsidized Loans; however, the College awarded the student $549 in Subsidized loans and $2,951 in Unsubsidized loans which resulted in an under award of $37 in Subsidized Loans and an over award of $37 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Waubonsee will ensure to add the loan fees first to ensure sub-loans are calculated correctly. Responsible Person for Corrective Action Plan Mary Greenwood Implementation Date of Corrective Action Plan 12/9/2025
1. Immediate System Correction The clock-to-credit hour conversion file in Banner (GTVSDAX) was reviewed and updated to include all applicable course prefixes, including MAH and PSY. This correction ensured that clock-to-credit hour conversions were calculated accurately for affected technical progr...
1. Immediate System Correction The clock-to-credit hour conversion file in Banner (GTVSDAX) was reviewed and updated to include all applicable course prefixes, including MAH and PSY. This correction ensured that clock-to-credit hour conversions were calculated accurately for affected technical programs. 2. Identification and Review of Impacted Students Financial Aid reviewed all students enrolled in the affected term (202610) and identified those whose federal aid hours had been overstated due to the conversion omission. 3. Correction of Federal Aid Awards Federal aid awards were recalculated for impacted students. The engagement team noted, and the College confirms, that all affected students were enrolled in a current payment period for which funds had not yet been fully drawn, allowing corrections to be made timely. 4. Resolution of Financial Impact Where recalculations resulted in reduced eligibility, institutional need-based funds were applied to affected student accounts to prevent students from incurring balances due to an internal administrative error. This ensured students were not financially penalized for the control deficiency. Preventive Actions and Controls to Avoid Recurrence To address the identified control deficiency and strengthen internal controls over clock-to-credit hour conversions, the College has implemented the following preventive measures: 1. Enhanced Curriculum Oversight The Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) now serve as standing members of the Academic/Curriculum Review Committee. This ensures that Financial Aid and Registrar review all proposed curriculum changes, including: o New courses o New course prefixes o Courses designated as “in degree plan” for technical or clock-hour programs This review occurs prior to course approval and implementation, allowing clock-to-credit hour implications to be addressed in advance. 2. Formal Notification and Review Process Academic Affairs will notify Financial Aid of any curriculum changes that may impact clock-to-credit hour conversions. Financial Aid will review and update Banner conversion tables as needed before federal aid calculations occur. 3. Assigned Responsibility and Monitoring Responsibility for maintaining and reviewing clock-to-credit hour conversion tables has been formally assigned to the Director of Financial Aid (Stacia Richerson). o Conversion tables will be reviewed each semester prior to awarding federal aid. o Discrepancies in ROAENRL will be reviewed promptly to ensure accuracy. 4. Ongoing Compliance Review The College will perform periodic reviews of conversion logic and awarding calculations to ensure continued compliance with federal regulations and internal control standards under 2 CFR 200.303. Conclusion Reid State Technical College has corrected the clock-to-credit hour conversion issue, resolved the related questioned costs, and implemented strengthened internal controls. The addition of the Registrar (Tara Dumas) and Director of Financial Aid (Stacia Richerson) to the Academic/Curriculum Review Committee, combined with formalized review and notification procedures, provides reasonable assurance that clock-to-credit hour conversions will be accurately applied prior to federal aid calculation and disbursement.
Management will have a heightened awareness of the deposits and transfers made from the EDA CARES Act RLF bank account. Management will ensure that loan payments are transferred to the EDA CARES Act RLF bank account in a timely fashion. Northeast Nebraska Economic Development District redrafted and ...
Management will have a heightened awareness of the deposits and transfers made from the EDA CARES Act RLF bank account. Management will ensure that loan payments are transferred to the EDA CARES Act RLF bank account in a timely fashion. Northeast Nebraska Economic Development District redrafted and resubmitted their ED-209 forms on December 18, 2025.
Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to...
Action Taken: Management agrees with the recommendations. The management team involved with grants will work to modify and improve the current procedures and will implement the controls surrounding grant compliance, from the application process through final reporting. The team will also continue to work to enhance our grant monitoring, including resuming management team meetings to keep everyone abreast of the status of grants. In addition, we will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements. Proposed Completion Date: June 30, 2026
Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will wor...
Action Taken: Management agrees with the recommendations. The unique situation with the COVID-19 funding, coupled with shifts in the business manager’s duties over the last few years and the staff retirement has resulted in grant report filings becoming a lower priority. The management team will work together and will resume management team meetings to determine and monitor the duties for which each is responsible. Strides have been made in this regard, as the principals have become involved in Federal program training, budgeting, and scheduling. Although the aforementioned report submissions are delinquent and funding was suspended, some filings have been completed, and certain payments have been received and others are forthcoming. However, management will begin to gradually involve the new business office employee in grant reporting to improve on compliance with grant reporting requirements. Proposed Completion Date: June 30, 2026
Finding Summary: When a recipient of Title IV assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must calculate the correct amount of Title IV grant or loan assistance that the student earned based on the ...
Finding Summary: When a recipient of Title IV assistance withdraws from an institution during a payment period or period of enrollment in which the recipient began attendance, the institution must calculate the correct amount of Title IV grant or loan assistance that the student earned based on the student’s withdrawal date and allocation of Title IV funds and return unearned funds to the Department of Education within 45 days. During the fiscal year 2025 period, one student that withdrew during the Fall term required a return of Title IV funds. However, the funds were not returned to the Department of Education within the required timeframe. Corrective Action Plan: Student Financial Aid management has developed a new master return of Title IV spreadsheet to ensure the return of funds and is routinely monitored by three different members of the Financial Aid Team. Anticipated Completion Date: The procedures will be implemented for the 2025-2026 Financial Aid Year. Responsible Parties: Ron Anderson
Due to the oversight of the fractional CFO, other priorities had taken precedence over other financial matters. However, with the recent appointment of a full-time CFO specifically focused on CICOA's financial operations, we can now shift our attention back to these important reporting responsibilit...
Due to the oversight of the fractional CFO, other priorities had taken precedence over other financial matters. However, with the recent appointment of a full-time CFO specifically focused on CICOA's financial operations, we can now shift our attention back to these important reporting responsibilities. The full-time CFO will ensure that all financial reporting deadlines are respected and met in a timely manner, allowing for greater accuracy and accountability in our financial practices. This change will help us enhance our financial oversight and maintain the integrity of our reporting processes moving forward.
Management’s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its policies and procedures to ensure that not only a...
Management’s Response: Management understands the importance of ensuring information is reported accurately and timely and the requirement to report to the NSLDS the enrollment status of students who receive federal funds. The College will review its policies and procedures to ensure that not only are status changes reported to the Clearinghouse, but also that the enrollment changes are reported appropriately from the National Student Clearinghouse to NSLDS. Views of Responsible Officials and Corrective Action: We will reassess controls, review these processes and implement controls, including multiple layers of review, to ensure that timely and accurate enrollment reporting is made. Furthermore, the reporting data was appropriately updated subsequent to the required timeframe. Name of Responsible Person: Jennifer O’Linger, Director of Student Financial Aid Implementation Date: Immediately
FINDING 2025-006 Finding Subject: Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials:...
FINDING 2025-006 Finding Subject: Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We were unaware of the required documentation at the onset of the ESSER grants. We were made aware during an ESSER construction monitoring audit. We made necessary changes per our corrective action plans from that audit for any future projects. Anticipated Completion Date: July 1, 2026
FINDING 2025-005 Finding Subject: Education Stabilization Fund – Earmarking Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of...
FINDING 2025-005 Finding Subject: Education Stabilization Fund – Earmarking Contact Person Responsible for Corrective Action: Mendy Shrout Contact Phone Number and Email Address): (765) 795-4664 / mshrout@cloverdale.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will be mindful of federal requirements in the future. We will label earmarked expenditures when setting up our accounts to more clearly document our expenditures. Anticipated Completion Date: July 1, 2026
FINDING 2025-005 Finding Subject: COVID-19 – Education Stabilization Fund – Special Test and Provision - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org View...
FINDING 2025-005 Finding Subject: COVID-19 – Education Stabilization Fund – Special Test and Provision - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The Education Stabilization Fund grant was completed during the audit period and the school district does not plan on receiving this award in the future. Therefore, further corrective action is not required and district officials will utilize this information to ensure compliance in other federal awards. Anticipated Completion Date: February 1, 2026
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