Corrective Action Plans

Finding 553757 (2024-001)

Material Weakness 2024

LA

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

The University has established policies and procedures to report a change in a student’s enrollment status in its next updated Enrollment Reporting roster. The University will take the necessary steps to ensure compliance with established policies and procedures with regard to reporting a change in ...

The University has established policies and procedures to report a change in a student’s enrollment status in its next updated Enrollment Reporting roster. The University will take the necessary steps to ensure compliance with established policies and procedures with regard to reporting a change in a student’s enrollment status.

View Audit 352339

Finding 553756 (2024-001)

Significant Deficiency 2024

Syracuse Cooperative Federal Credit Union

PA

Questioned Costs Matching / Level of Effort / Earmarking

The Credit Union will update the record retention policy, and provide additional training to staff regarding retention requirements to ensure records are destroyed according to the policy schedule.

View Audit 352323 Questioned Costs: $1

Finding 553705 (2024-002)

None 2024

American Indian Community Housing Organization

MN

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.302 § 200.305 § 200.317 § 200.326

Corrective Action Plan We are in the process of updating the Organization’s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2025

View Audit 352313

Finding 553699 (2024-002)

Significant Deficiency 2024

Invest in Kids

CO

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.303

Invest in Kids updated its policies and procedures in October 2024. The updated language states “Disbursements to subrecipients of federal funds: The Director(s) and Finance & Administrative Manager will review all relevant documentation to confirm that funds were used for the approved amount and in...

Invest in Kids updated its policies and procedures in October 2024. The updated language states “Disbursements to subrecipients of federal funds: The Director(s) and Finance & Administrative Manager will review all relevant documentation to confirm that funds were used for the approved amount and intended activity, goods, or services, and that only allowable expenses are charged. Invoice payments will be delayed until the necessary supporting documentation is received and verified.” Additionally, all staff participated in the organization's annual financial management and internal controls training in October 2024 with a focus on the accounts payable and invoicing process.

View Audit 352269 Questioned Costs: $1

Finding 553698 (2024-001)

Significant Deficiency 2024

Invest in Kids

CO

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

Invest in Kids updated its human resources system to ensure timesheets accurately reflect time allocated across various funding sources and cost objectives. Additionally, all staff attended the organization’s annual financial management and internal controls training in October 2024, that included u...

Invest in Kids updated its human resources system to ensure timesheets accurately reflect time allocated across various funding sources and cost objectives. Additionally, all staff attended the organization’s annual financial management and internal controls training in October 2024, that included updated policies and a focus on accurate submissions of time and effort. Policy reviews have also been completed by management.

View Audit 352269 Questioned Costs: $1

Finding 553682 (2024-002)

Significant Deficiency 2024

Lane College

TN

Reporting Student Financial Aid Matching / Level of Effort / Earmarking

Lane College acknowledges the audit finding regarding delayed reporting of withdrawal and graduation dates to the National Student Loan Data System (NSLDS). The College recognizes the importance of timely and accurate reporting as a critical compliance requirement under 2 CFR Part 200 and the compli...

Lane College acknowledges the audit finding regarding delayed reporting of withdrawal and graduation dates to the National Student Loan Data System (NSLDS). The College recognizes the importance of timely and accurate reporting as a critical compliance requirement under 2 CFR Part 200 and the compliance supplement. In response to this audit finding, Lane College commits to implementing immediate and sustained corrective actions as follows: 1. Enhanced Tracking System: Lane College will implement a robust tracking system specifically designed to monitor student enrollment status changes, including withdrawals and graduations, to ensure these changes are promptly identified and reported. The tracking system will be integrated within the existing enrollment management software, enabling automatic notifications to designated staff when an enrollment status change occurs. 2. Internal Control Improvements: The College will strengthen internal controls by clearly delineating responsibilities for enrollment reporting among relevant departments. The Registrar's Office will have primary accountability for overseeing timely reporting, supported by coordinated 3. checks and balances from the Financial Aid Office to cross-verify reporting accuracy and timeliness. 4. Staff Training: Regular training sessions will be conducted for all staff involved in reporting enrollment status changes. These trainings will focus on compliance requirements, reporting timelines, and use of the updated tracking and reporting system. Attendance will be mandatory, and training effectiveness will be evaluated through periodic assessments. 5. Periodic Audits: To sustain compliance, the College will institute internal audits conducted quarterly by the Office of Enrollment Management. These audits will sample enrollment status changes and assess the timeliness of reports submitted to NSLDS. Audit results will be documented, reviewed by senior management, and any deviations will be promptly addressed. 6. Reporting Accountability: Staff responsible for reporting enrollment status changes will be required to submit monthly summaries of reporting activities to their supervisors. Supervisors will review these summaries to ensure adherence to the 60-day reporting deadline and address any delays proactively. Lane College is committed to rectifying this compliance issue swiftly and effectively. The College understands that maintaining accurate and timely reporting to NSLDS is essential to prevent inaccuracies in student loan records, avoid potential financial consequences, and uphold regulatory compliance. These measures demonstrate our dedication to robust compliance practices and continuous institutional improvement.

View Audit 352252

Finding 553657 (2024-005)

Material Weakness 2024

University of Puerto Rico

PR

Student Financial Aid Special Tests & Provisions Reporting

Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Compliance Requirement - Enrollment Reporting Management’s Response The UPR concurs with this finding. On February 26, 2025, we met with all deans for Academic Affairs and explained to them the importance of complying with ...

Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Compliance Requirement - Enrollment Reporting Management’s Response The UPR concurs with this finding. On February 26, 2025, we met with all deans for Academic Affairs and explained to them the importance of complying with federal requirements. Twenty-two exceptions were found in the FY2023 single audit report, and an exception was found in FY2024 single audit report. We recognize that we have improved, however, we are not satisfied with the results. We understand that we have not achieved 100% compliance, and our correction action plan remains in force. We will take additional actions such as: • Continue to guide professors on the importance of taking and reporting attendance timely. • One of the special assistants of the Vice Presidency for Academic Affairs will send a reminder to the registrars every month indicating how much time they have left to inform the NSLDS of the change in status on or before 60 days after the change occurred. • The next meeting of the University Board will be used to inform members (chancellors, faculty, and student representatives) so that they can take the message to their institutional units. The goal is to have 100% compliance. Responsible Person or Office: Executive Vice President for Academic Affairs and Research. Timeline: 2025-2026

View Audit 352239

Finding 553656 (2024-004)

Material Weakness 2024

University of Puerto Rico

PR

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

Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Compliance Requirement - Return of Title IV Funds Management’s Response The UPR concurs with this finding. Since April 2024, Río Piedras implemented the following procedure for students who request a total withdrawal. 1. T...

Federal Program: Student Financial Assistance (SFA) Cluster - Various ALN Compliance Requirement - Return of Title IV Funds Management’s Response The UPR concurs with this finding. Since April 2024, Río Piedras implemented the following procedure for students who request a total withdrawal. 1. The information system office produces a list of students who request total withdrawal. 2. This list is received by the financial aid office. 3. The financial aid office identifies the students with financial aid. 4. The financial aid office sends to the fiscal financial aid office the students who requested total withdrawal and received financial aid. 5. The fiscal financial aid office analyzes the cases and prepares the R2T4 form. 6. The finance office returns the determined amount to ED using the G5 platform. This procedure worked well for students who requested a total withdrawal but did not prevent another case in Río Piedras noted by the auditor in which the student never attended his courses (Note: The three additional cases of Río Piedras in which the student requested total withdrawal occurred before the implementation of this process (April 2024)). Neither will work for another case identified by the auditors for which the student stopped attending on the Mayagüez campus. For the three cases of the Cayey campus in which the student requested a total withdrawal and the funds were returned after 45 days, the employee in charge was a new employee in the fiscal office without direct supervision because her supervisor, the finance director, was on maternity leave. Currently, the Cayey campus has a finance coordinator, a position between the fiscal office director and the finance director. The finance coordinator will directly supervise the fiscal office. In his or her absence, the director will oversee the fiscal office. In May 2025, the finance office at central administration will have a meeting with the finance directors and fiscal financial aid directors to discuss this finding and establish a uniform procedure to address: • Students who requested total withdrawal. • Students who stopped attending. • Students who never attended. Responsible Person or Office: Finance office at the central administration and finance offices at each of the eleven (11) institutional units. Timeline: 2025-2026

View Audit 352239

Finding 553654 (2024-002)

Material Weakness 2024

University of Puerto Rico

PR

Cash Management Subrecipient Monitoring Matching / Level of Effort / Earmarking

Federal Programs: Student Financial Assistance (SFA) Cluster - Various ALN COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Compliance Requirement – Cash Management Management’s Response The UPR concurs with this finding. In two instances, UPR requested funds to G5 with too much ...

Federal Programs: Student Financial Assistance (SFA) Cluster - Various ALN COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Compliance Requirement – Cash Management Management’s Response The UPR concurs with this finding. In two instances, UPR requested funds to G5 with too much time in advance. The central administration finance office asked for all units' payment schedules. We will review them and, if necessary, request that schedules include the date to request funds to G5 and the payment date. Schedules must be approved and signed by a finance director’s representative. Staff from the financial aid, fiscal affairs, finance, and disbursement offices will be trained on the FSA Handbook, specifically about requesting and managing FSA funds. We will discuss potential errors that may occur during the process and how, as a group, they can monitor and prevent missed payment deadlines. For example, if the finance office receives G5 funds before the scheduled date, the payment date to students must be brought forward. This type of monitoring and awareness of potential non-compliance should result in compliance with the regulations. Responsible Person or Office: Finance office at the central administration and finance offices at the eleven (11) institutional units. Timeline: 2025-2026

View Audit 352239

Finding 553638 (2024-004)

Significant Deficiency 2024

Anna Marie's Alliance

MN

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024-004 Crime Victim Assistance -Assistance Listing No. 16.575 Recommendation: A separate individual with supervisory authority over the preparer should be assigned to review a...

2024-004 Crime Victim Assistance -Assistance Listing No. 16.575 Recommendation: A separate individual with supervisory authority over the preparer should be assigned to review and approve the cash drawdowns and reports prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has designated an individual to review and approve the cash reimbursement requests and reports prior to submission. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2025. If the U.S. Department of Justice has questions regarding this plan, please call Tracy Johnson at 320- 251-7203 ext. 257.

View Audit 352209

Finding 553636 (2024-002)

Significant Deficiency 2024

Anna Marie's Alliance

MN

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency § 200.318 § 200.326

SIGNIFICANT DEFICIENCY 2024-002 Crime Victim Assistance -Assistance Listing No. 16.575 Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG...

SIGNIFICANT DEFICIENCY 2024-002 Crime Victim Assistance -Assistance Listing No. 16.575 Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2025

View Audit 352209

Finding 553628 (2024-001)

None 2024

Nashoba Regional School District

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.309

Finding 2024-001 Condition: Costs were recorded for service periods prior to grant approval date. Corrective Action Planned: The district will implement controls to prevent the recording of costs for service periods prior to grant approval date by written guidance to all staff involved in federal ...

Finding 2024-001 Condition: Costs were recorded for service periods prior to grant approval date. Corrective Action Planned: The district will implement controls to prevent the recording of costs for service periods prior to grant approval date by written guidance to all staff involved in federal grant funds. Please note, that the practice at question is not in violation of school committee policy as we have not made any expenditures outside that entity’s approval date. Anticipated Completion Date: By July 1, 2025 Contact: Ross Mulkerin, Director of Finance and Operations

View Audit 352205 Questioned Costs: $1

Finding 553626 (2024-004)

Significant Deficiency 2024

Town of Bridgwater, Vermont

VT

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

Finding: 2024-004 Written Financial Policies- Activitities Allowable, Allowable Cost Name of responsible official: Melissa Spear -Treasurer Corrective action: Adopt suggested policies as outlined by auditor. Anticipated completion date: June 30, 2025

View Audit 352202

Finding 553612 (2024-003)

Material Weakness 2024

Seda Council of Governments

PA

Matching / Level of Effort / Earmarking

U.S DEPARTMENT OF COMMMERCE COVID-19-Economic Development Administration- CARES RLF - Assistance Listing No. 11.307, Grant period - Year ended June 30, 2024. See finding 2024-002 – listed below. ALLOWANCE FOR UNCOLLECTIBLE LOANS Recommendation: When management determines a loan is uncollectible, the...

U.S DEPARTMENT OF COMMMERCE COVID-19-Economic Development Administration- CARES RLF - Assistance Listing No. 11.307, Grant period - Year ended June 30, 2024. See finding 2024-002 – listed below. ALLOWANCE FOR UNCOLLECTIBLE LOANS Recommendation: When management determines a loan is uncollectible, they should ensure an allowance is recorded. Management Response: Management concurs with finding. Planned Corrective Action: The Finance Department will include the Fiscal Manager and Fiscal Controller in any communications regarding problematic loans to ensure proper reporting. Persons Responsible: Jamie Carnes, Fiscal Controller Anticipated Completion Date: March 31, 2025.

View Audit 352193

Finding 553590 (2024-002)

Significant Deficiency 2024

City of Dowagiac

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Equipment & Real Property Management

Finding 2024-002 Significant Deficiency and Noncompliance - Lack of Required Uniform Guidance Policies and Procedures Condition: The City did not update their federal policies and procedures to be in full compliance with Uniform Guidance. Anticipated Completion Date: September 30, 2025 Corrective Ac...

Finding 2024-002 Significant Deficiency and Noncompliance - Lack of Required Uniform Guidance Policies and Procedures Condition: The City did not update their federal policies and procedures to be in full compliance with Uniform Guidance. Anticipated Completion Date: September 30, 2025 Corrective Action: The City will implement a new policy document specifically for Uniform Grant Compliance to have one document to ensure compliance.

View Audit 352186

Finding 553579 (2024-006)

Material Weakness 2024

City of South Portland, Maine

ME

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

Management’s Response/Corrective Action Plan: Management will have staff prepare monthly personnel activity reports for time worked on grants and will review and adjust budgeted payroll allocations accordingly. Monthly budget report have already been set up on the Google Drive for management and sta...

Management’s Response/Corrective Action Plan: Management will have staff prepare monthly personnel activity reports for time worked on grants and will review and adjust budgeted payroll allocations accordingly. Monthly budget report have already been set up on the Google Drive for management and staff to access and review.

View Audit 352169

Finding 553572 (2024-007)

Significant Deficiency 2024

City of South Portland, Maine

ME

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

Management’s Response/Corrective Action Plan: The Director and Operations Manager abruptly left in spring of 2024 and the City contracted with Greater Portland Metro to run the service until we could determine next steps. The City Council approved joining Greater Portland Metro in September 2024, e...

Management’s Response/Corrective Action Plan: The Director and Operations Manager abruptly left in spring of 2024 and the City contracted with Greater Portland Metro to run the service until we could determine next steps. The City Council approved joining Greater Portland Metro in September 2024, effective January 2025. The City no longer has a bus service.

View Audit 352169

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.

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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.

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Corrective Action Plans

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