Corrective Action Plans

Finding 537931 (2024-001)

Material Weakness 2024

AR

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Finding 2024-001 Responsible Party: Kyle McCarn, Superintendent Corrective Action Plan: Viola School District will make certain that all federal purchasing laws are followed. Correct protocol will be followed from this point moving forward. Completion Date for Corrective Action Plan: March 6th, 202...

Finding 2024-001 Responsible Party: Kyle McCarn, Superintendent Corrective Action Plan: Viola School District will make certain that all federal purchasing laws are followed. Correct protocol will be followed from this point moving forward. Completion Date for Corrective Action Plan: March 6th, 2025

View Audit 348985

Finding 537874 (2024-001)

Significant Deficiency 2024

Hobart and William Smith Colleges

NY

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

CORRECTIVE ACTION PLAN U.S. Department Education Hobart and William Smith Colleges respectfully submit the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully's Trail Pittsford, NY 14534 Audit peri...

CORRECTIVE ACTION PLAN U.S. Department Education Hobart and William Smith Colleges respectfully submit the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully's Trail Pittsford, NY 14534 Audit period: July 1, 2023 - June 30, 2024 The findings from the 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS SIGNIFICANT DEFICIENCY 2024-001 Timely Return of Title IV Funds Recommendation: We recommend that the Colleges assess and address staffing levels in the Student Financial Aid Department to ensure adequate resources are available to process Title IV fund returns timely. Additionally, the Colleges should develop policies and procedures to ensure timely processing of returns within the required 45-day period. Corrective Action Plan: Additional staffing has been put in place to ensure that we have enough resources to complete title IV refund processing in a timely fashion. A new assistant director (hired in November 2024) will be monitoring the notifications that students have withdrawn and notify the director when title IV refunds are required. The new assistant director is also currently being trained in title IV refund processing and has experience with title IV refunding prior to being hired. The associate director (hired in July 2024) is also an expert in the return of federal funding through EDCONNECT and perform a supportive role in this process. Lisa Hoskey, Director of Financial Aid, is responsible for implementing this plan and can be reached at Hoskey@hws.edu.

View Audit 348956

Finding 537671 (2024-001)

Material Weakness 2024

Town of Webster

MA

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

DISTRICT RESPONSE: Finding 2024-001 Condition: The District recognizes that Time and Effort certifications were not maintained for grant funded employees that had salaries funded by the FC 240 and 262 grants, which are federal special education entitlement grants that fall under the Individuals wi...

DISTRICT RESPONSE: Finding 2024-001 Condition: The District recognizes that Time and Effort certifications were not maintained for grant funded employees that had salaries funded by the FC 240 and 262 grants, which are federal special education entitlement grants that fall under the Individuals with Disabilities Act (IDEA). Corrective Action Plan: The special education entitlement grants (FC 240 and 262) require certification of Time and Effort on a tri-annual basis (fall, spring, summer). The District has put into place a certification process, effective Spring of 2025, that will capture Time and Effort of all grant funded employees that have salaries funded by the FC 240 and 262 grants. This process included the development of certification records in which grant funded employees will be able to document and certify that they have been working solely in activities supported by the FC 240 or 262 grants during each of the tri-annual reporting periods. The certification record will be signed by the Director of Student Support Services as an after-the fact determination of actual effort expended for the grants on a tri-annual basis.The certification records will be kept on file in the Office of Student Support Services. Anticipated Completion Date: Process verified on 3/18/2025. Time and Effort will be maintained on a tri-annual basis. Contact: Shari Haire Director of Student Support Services 77 Poland Street Webster, MA 01570 508-943-3646 ext. 4022 shaire@webster-schools.org

View Audit 348944 Questioned Costs: $1

Finding 537667 (2024-007)

Material Weakness 2024

Ringling School District I-14

OK

Special Tests & Provisions Material Weakness Matching / Level of Effort / Earmarking

The District will review federal expenditures and ensure that construction projects are not being paid with funds unless the proper language has been in the construction contract and certified payrolls have been obtained. Future projects will be reviewed to ensure compliance with the Davis Bacon ...

The District will review federal expenditures and ensure that construction projects are not being paid with funds unless the proper language has been in the construction contract and certified payrolls have been obtained. Future projects will be reviewed to ensure compliance with the Davis Bacon Act.

View Audit 348940

Finding 537643 (2024-003)

Significant Deficiency 2024

Northern Illinois University

IL

Reporting Matching / Level of Effort / Earmarking Student Financial Aid § 200.303

Finding 2024-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (the University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not identif...

Finding 2024-003 Errors in Reporting for NSLDS Condition: Northern Illinois University (the University) did not properly report enrollment changes for certain students who received federal student aid to the National Student Loan Data System (NSLDS) and the internal controls in place did not identify the errors. Corrective Action Plan: University has taken the following corrective actions that will eliminate all material exceptions: 1) The University will correct the software issue which caused some students with the new withdrawal grade code to not have a withdrawal status calculated correctly at the campus level. 2) The University will provide additional training and guidance to address the misinterpretation of withdrawal status effective date reporting which caused an error at the program level. Individual(s) Responsible for Corrective Action: Registration and Records Staff Anticipated Completion Date: June 30, 2025

View Audit 348932

Finding 537628 (2024-001)

Significant Deficiency 2024

Lawrence Union Free School District

NY

Procurement, Suspension & Debarment Cash Management Significant Deficiency § 200.303

Significant Deficiency 2024-001. Procurement United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondar...

Significant Deficiency 2024-001. Procurement United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Youth and Children ALN: 84.425W Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District’s Assistant Superintendent for Business and Operations will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure that District policies are in compliance with these guidelines. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: June 30, 2025.

View Audit 348909

Finding 537624 (2024-001)

Material Weakness 2024

West Branch Local School District

OH

Eligibility School Nutrition Programs Matching / Level of Effort / Earmarking

All free and reduced lunch applications are entered electronically to PaySchools by the parent/guardian of the child. They input their own financial information. We as a school choose the guidelines in the program, which is the exact information given to us by the State of Ohio to determine eligib...

All free and reduced lunch applications are entered electronically to PaySchools by the parent/guardian of the child. They input their own financial information. We as a school choose the guidelines in the program, which is the exact information given to us by the State of Ohio to determine eligibility. Because PaySchools does not have a SOC1 report for Ohio, we must physically verify all applications, so what we will start doing as of 2/26/2025 is the treasurer’s office staff and the food service director will do what we did before this technology existed and print them out on paper and do the same math the computer program did and paid money for to verify the same information the program already determined to make sure the program verified the information correctly. Because this process is starting as of 2/26/205, the treasurer’s office staff will review all of the applications prior to 2/26/2025.

View Audit 348894

Finding 537614 (2024-003)

Significant Deficiency 2024

Missouri Valley College

MO

Student Financial Aid Matching / Level of Effort / Earmarking

2024-003 Plan: As of 03/20/2025 this is complete. Objective: Ensure that there is a recorded time date stamp of the notification itself. Process: To implement this in an effective and accurate setup we will execute the Batch Assign Transmittal CM Codes (BATC) process to improve communication code as...

2024-003 Plan: As of 03/20/2025 this is complete. Objective: Ensure that there is a recorded time date stamp of the notification itself. Process: To implement this in an effective and accurate setup we will execute the Batch Assign Transmittal CM Codes (BATC) process to improve communication code assignment and correspondence management. To implement the Batch Assign Transmittal CM Codes (BATC) process, we will execute the BATC process immediately following the completion of the transmittal, ensuring all necessary parameters are set accurately. Next, we will establish a communication code through the Communication Management Center (CMC), with IT Support responsible for associating an immediate print document with the code. This setup will leverage the options available within the BATC system, including assignment to specific awards, categories, and exclusions as needed. Subsequently, we will utilize BATC to identify recipients for the communication code by setting parameters based on academic year, date ranges, award periods, and award categories. Once recipients are identified, we will verify that all students are included by checking the TA.ACYR file and the relevant code and date fields to ensure no omissions. Following this verification, we will assign the communication code within the CRI system, ensuring the status is marked as "Received" so that the immediate print document can be scheduled as pending correspondence. The next step involves managing the correspondence through the PCB process, with the option to use PCEX if necessary. It's important to ensure that the immediate print document is configured for email distribution. A review of the entire process will then be conducted by the office staff, analyzing outcomes and gathering feedback from team members to document any issues encountered and the resolutions applied. Finally, we will focus on continuous improvement, implementing feedback to address any problematic areas and scheduling a training session if required to cover the BATC and communication code processes. This structured approach aims to streamline operations and enhance accuracy in communication code assignments. This outlines the steps necessary to streamline the BATC process and enhance accuracy in communication code assignments. Regular reviews and adjustments based on team feedback will ensure ongoing improvement.

View Audit 348884

Finding 537590 (2024-005)

Material Weakness 2024

Metropolitan School District of Shakamak

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2022-005 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Brian Rehmel, Maintenance Supervisor Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding, Description of Corrective Action Plan: The Superintendent and Ma...

FINDING 2022-005 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Brian Rehmel, Maintenance Supervisor Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding, Description of Corrective Action Plan: The Superintendent and Maintenance Supervisor will begin ensuring all vendor contracts with labor installation in excess of $2,000 which are funded by federal grants including Davis Bacon Wage Rate Requirement clauses and implement a formal review process to ensure the required weekly payroll reports certifications are collected and reviewed to ensure compliance with federal regulations Anticipated Completion Date: Immediate review will begin of all vendor contracts funded by federal grants.

View Audit 348863

Finding 537587 (2024-004)

Material Weakness 2024

Metropolitan School District of Shakamak

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328

FINDING 2022-004 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Jennifer Barcus, Corporation Treasurer; Jeri Morin, Data Coordinator Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding. Description of Corrective Action P...

FINDING 2022-004 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Jennifer Barcus, Corporation Treasurer; Jeri Morin, Data Coordinator Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Superintendent will prepare all annual data reports and have a documented formal review from the Corporation Treasurer and the Data Coordinator, prior to submission, to validate the accuracy and completeness of the data submitted. Anticipated Completion Date: Immediate review will begin of all annual data reports.

View Audit 348863

Finding 537575 (2024-001)

Material Weakness 2024

Stetson University, Inc.

FL

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding: 2024-001 Suspension and Debarment Condition: The University was not able to provide an audit trail to support the verification that a vendor was not suspended and debarred before entering into a contract. Anticipated Completion Date: Implemented in October 2024. Person Responsible: Carol Bu...

Finding: 2024-001 Suspension and Debarment Condition: The University was not able to provide an audit trail to support the verification that a vendor was not suspended and debarred before entering into a contract. Anticipated Completion Date: Implemented in October 2024. Person Responsible: Carol Buckels, Director of Grants, Sponsored Research & Strategic Initiatives Corrective Actions Taken or Planned: The Sponsored Research Administration Office (SRA) ensures all purchases, reimbursements, and any other expenditure submitted for payment are first approved by the Principal Investigator (PI). SRA will review the approved budget to ensure funding is available. If the payment request is for purchases that require payment to specific vendors, the SRA verifies that the entity being used for these purchases is not suspended or debarred, or otherwise excluded from participating in the transaction. This verification is accomplished by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA). SRA submits the verification along with the purchasing request or check request to accounts payable or purchasing for processing. If the expenditure amount is above the SRA approval level, the request is then escalated for additional approval (Director of Academic Administration, Provost, etc.) before sending to accounts payable or purchasing for processing.

View Audit 348854

Finding 537525 (2024-001)

Significant Deficiency 2024

John F. Kennedy Center for Performing Arts

DC

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.308 § 200.403

2024-001 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Contacts: Regina Frazier Title: Payroll Manager Anticipated Completion Date: September 2025 Corrective Action: The Center is dedicated to maintaining compliance wi...

2024-001 – Internal Control over Compliance and Compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Contacts: Regina Frazier Title: Payroll Manager Anticipated Completion Date: September 2025 Corrective Action: The Center is dedicated to maintaining compliance with federal regulations concerning allowable and unallowable activities and costs. In response to the recent audit finding, the Center’s payroll department will proactively engage with key stakeholders in high-risk areas prior to the start of the fiscal year. This engagement will involve reviewing payroll submission templates and ensuring that the rates align with the most current employment agreements. Status as of March 2025: All affected employees have been reimbursed, and key stakeholders in high-risk areas have been informed of the corrective action plan.

View Audit 348794

Finding 537520 (2024-001)

Significant Deficiency 2024

City of Glendale

CA

Matching / Level of Effort / Earmarking

In October 2024, the City hired a new staff member to conduct monitoring operations, and inspections resumed in late October 2024.

View Audit 348749

Finding 537519 (2024-001)

None 2024

William Marsh Rice University

TX

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

William Marsh Rice University Response The following is William Marsh Rice University’s Response to the audit of Federal programs in accordance with the Uniform Guidance for the year ended June 30, 2024. Finding 2024-001 – Loan Disbursement Notification Cluster: Student Financial Assistance Cluster ...

William Marsh Rice University Response The following is William Marsh Rice University’s Response to the audit of Federal programs in accordance with the Uniform Guidance for the year ended June 30, 2024. Finding 2024-001 – Loan Disbursement Notification Cluster: Student Financial Assistance Cluster Awarding Agency: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2023 – June 30, 2024 Assistance Listing Number: 84.268 Pass-through Entity: Not applicable We acknowledge the audit finding regarding the missing documentation of the loan disbursement notification for the 2023-2024 academic year. The issue began when an automated rule was disabled by a system update. This prevented the loan disbursement notices from being sent to students. Upon recognizing the underlying reason, the loan disbursement notice, which is sent one day after a loan disbursement posts to a student’s account, had its system rules reengaged. This was achieved through a collaborative effort involving the Office of Financial Aid, the Bursar's Office, and Administrative Systems. Notices resumed on September 26, 2024, and we have since conducted spot checks to confirm that the notices are being sent as required. To prevent a recurrence of this issue, we have implemented the following measures: 1. Annual Review: We have updated our staff calendar with an annual reminder to review and request updates to the text and rules of the loan disbursement notice. 2. Documentation: We have ensured that the scheduled disbursement dates and the right to cancel are disclosed in multiple areas, including the all-freshmen notice, other loan/aid award notices, the loan section of our website, and the financial aid section of General Announcements for both undergraduate and graduate students. Prior to and including the 2023-2024 academic year, this information has been updated and made available on an annual basis in these areas. This practice will continue. Effective Date: September 26, 2024 Person(s) responsible for implementation: Paul Negrete, Executive Director for University Financial Aid Services, 713-348-5905 We believe these actions address the audit finding and will help maintain compliance with notification requirements moving forward. Sincerely, Paul Negrete Executive Director University Financial Aid Services

View Audit 348737

Finding 537488 (2024-003)

Significant Deficiency 2024

City and Borough of Juneau, Alaska

AK

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.306

FEDERAL AWARD FINDING Finding: 2024-003 Significant Deficiency in Internal Controls over Compliance and Compliance – Setup and Monitoring of Reporting and Match Name of Contact Person: Angie Flick, Director of Finance Corrective Action: The accountants will be going through additional training on se...

FEDERAL AWARD FINDING Finding: 2024-003 Significant Deficiency in Internal Controls over Compliance and Compliance – Setup and Monitoring of Reporting and Match Name of Contact Person: Angie Flick, Director of Finance Corrective Action: The accountants will be going through additional training on setting up grants in the system and how to reconcile them. CBJ will also be completing a grant reconciliation process quarterly instead of annually. This will act both as a control as well as an opportunity to make timely corrections in the case of error. Proposed Completion Date: September 30, 2025

View Audit 348728

Finding 537480 (2024-001)

Significant Deficiency 2024

Imperial Valley Regional Occupational Program

CA

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.430

The plan will be to do several things in order to correct the issue. Hold training for management and clerical staff on updates to timesheet and time accounting protocols to ensure understanding of the processes. Have staff and management update timesheets to include the source of funding, the na...

The plan will be to do several things in order to correct the issue. Hold training for management and clerical staff on updates to timesheet and time accounting protocols to ensure understanding of the processes. Have staff and management update timesheets to include the source of funding, the name of the project and resource code applicable to the project. Have management and clerical staff verify information on timesheets and sign and date the timesheets once verified.

View Audit 348697

Finding 537474 (2024-003)

Material Weakness 2024

Southwestern Adventist University

TX

Student Financial Aid Material Weakness Reporting

Corrective Action: See above corrective action plans for 2024-001 and 2024-002. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar

View Audit 348681

Finding 537470 (2024-001)

None 2024

Southwestern Adventist University

TX

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

Corrective Action: Here are the immediate corrective actions taken: • There are now appropriate staffing levels in the Records office. Training is up-to-date as well. • A thorough review of the reporting requirements and a step-by-step guide was made by ITS and the Registrar to ensure NSC reports ...

Corrective Action: Here are the immediate corrective actions taken: • There are now appropriate staffing levels in the Records office. Training is up-to-date as well. • A thorough review of the reporting requirements and a step-by-step guide was made by ITS and the Registrar to ensure NSC reports are correct and meet the NSC requirements. • The missing NSLDS reports for the 2022-2023 academic year have been prepared and submitted. 2023-24 academic year were prepared and submitted as of 2/11/2025. The 2024-2025 academic year will be prepared and submitted by the end of the Spring 2025 semester. • Coordination with the NSC representatives to ensure the validity and accuracy of the reports in compliance with submission requirements and verification of report acceptance. To prevent future occurrences of missed NSLDS reporting, the following steps have been implemented: • Responsibility: The registrar is the primary reporting coordinator to the National Student Clearinghouse, with support from both Student Financial Services and ITS. • Automated Reminders: Calendar alerts and task management reminders are sent monthly to notify responsible staff well in advance of reporting deadlines this includes the Registrar, Student Financial Services and ITS. • Training and Documentation: A standard operating procedure (SOP) has been documented to guide future reporting efforts. However, ITS must make it a priority when there are changes to NSC reporting requirements. This was lacking during the 2022-2024 periods the university failed to report. • Management Oversight: The Vice President for Academic Administration must also ensure that all these processes and departments are working to ensure the student data is being reported correctly and on-time. We are confident that these measures will address the issue of failure to report to the NSC and ensure full compliance with NSLDS reporting requirements in the future. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar Completion Date: February 11, 2025

View Audit 348681

Finding 537469 (2024-002)

None 2024

Southwestern Adventist University

TX

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

Corrective Action: Financial aid will be processed on or after census day (12th day of enrollment period) for all students identified by the Registrar and financially cleared as enrolled as of that date. The Registrar will ensure students listed as enrolled as of census date, are registered and att...

Corrective Action: Financial aid will be processed on or after census day (12th day of enrollment period) for all students identified by the Registrar and financially cleared as enrolled as of that date. The Registrar will ensure students listed as enrolled as of census date, are registered and attending classes. Student Finance has learned to identify anomalies within the Ellucian system that caused the system to not auto-adjust to account for student eligibility. More staff training will be done in Student Finance to review awarding, to prevent this as an ongoing issue. Contact Persons: Duane Valencia, Assistant Financial Vice President – Student Finance Jason Kowarsch, Registrar Completion Date: To be completed by June 1, 2025

View Audit 348681

Finding 537467 (2024-002)

Significant Deficiency 2024

Delaware Valley University

PA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Finding 2024-002 Name of Responsible Individual: James Slizewski, Registrar Corrective Action: The University has implemented several corrective actions to address this finding. We have created a comprehensive process document to ensure accurate reporting of student enrollment changes. This document...

Finding 2024-002 Name of Responsible Individual: James Slizewski, Registrar Corrective Action: The University has implemented several corrective actions to address this finding. We have created a comprehensive process document to ensure accurate reporting of student enrollment changes. This document outlines each step of the reporting process in detail, providing clear guidelines and procedures for staff to follow for each type of enrollment report that is required. This document will also outline a procedure for conducting reviews of student status changes to ensure they align with our reported data. These reviews will involve cross-checking the information in our reporting system with data generated by our student information system’s delivered enrollment reporting process to identify discrepancies prior to submitting the report. Additionally, we are seeking training and outside consultation on how to better utilize our student information system more effectively. We will engage with consultants to improve our student information system’s delivered student withdrawal and enrollment reporting processes. By utilizing our student information system’s delivered processes more effectively, we will reduce future enrollment reporting errors. Anticipated Completion Date: February 2025

View Audit 348680

Finding 537462 (2024-003)

Significant Deficiency 2024

Fontbonne University

MO

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management

Corrective Action Plan 2024-003: The University concurs with the finding and has made the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed ...

Corrective Action Plan 2024-003: The University concurs with the finding and has made the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed on the disbursement screen for these students and pass that to COD. The University has implemented a control to complete the disbursements each time and then verify the date reflects correctly in COD afterwards. While this should be an automatic process, and has been in previous years, it will be something the University verifies now with each aid posting. Completion Date: August 2024 Contact Person: Megan Morton, Director of Financial Services

View Audit 348677

Finding 537460 (2024-003)

Significant Deficiency 2024

State System of Higher Education, Commonwealth of Pennsylvania

PA

Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency § 200.303

Commonwealth: Direct Loan processor will submit monthly reconciliations to Executive Director of Financial Aid or designated campus director for review and approval

View Audit 348667

Finding 537458 (2024-002)

Significant Deficiency 2024

State System of Higher Education, Commonwealth of Pennsylvania

PA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

ESU: The University acknowledges this is a repeat finding. While a corrective action plan was implemented in May 2024, the audit sample consisted of students from Fall 2023 and Spring 2024, before the updated procedures were in effect. Since then, the University has enhanced its process for identify...

ESU: The University acknowledges this is a repeat finding. While a corrective action plan was implemented in May 2024, the audit sample consisted of students from Fall 2023 and Spring 2024, before the updated procedures were in effect. Since then, the University has enhanced its process for identifying when a student ceases participation in a course. Faculty are now required to indicate when a student stops attending. If a faculty member and student agree on issuing an incomplete grade, both must sign a document attesting that the incomplete is a valid final grade. This ensures clarity for the Registrar's Office. Registrar staff now update the National Student Clearinghouse promptly once a student’s last date of activity is confirmed, particularly when a student withdraws from all courses. This process supports timely compliance with the 60-day federal reporting requirement. Additionally, the University is reviewing its procedures for reporting program enrollment effective dates to ensure consistency with NSLDS standards. All updates are submitted through the National Student Clearinghouse. IUP: IUP will set guidelines that all degree clearing must be done with the 45 day time line so the students are reported within the 60 days limit Cheyney: Cheyney University of Pennsylvania extracts current enrollment information, including any enrollment status changes for all students from the University system of record based on the schedule timeline provided to NSC. As of Fall 2024, The Registrar’s Office continues to review NSC information following transmission, particularly for effective dates of completely withdrawn students. The NSC reports enrollments to NSLDS for the University. Cheyney University had previously learned that NSLDS did not receive students' enrollment status changes from NSC in a timely manner due the University HCM2 status and timing of students being reported to NSLDS from COD based on Ed’s approval of the University HCM2 submissions Kutztown: We will shorten our process to 2-3 days to compensate from the (up to) 30 day lag between NSC reporting and NSLDS reporting. We will connect with another PASSHE school (not on the findings report) to ascertain how they keep their submissions timely, and learn best practices. We will renew our cooperative efforts with financial aid to ensure both sides of the equation – NSC and NSLDS – are communicating and that both offices are involved in double checking. Commonwealth: The issues with enrollment reporting were one-time issues related to the integration of the three schools and the implementation of and data migration to a new student information system. Issues have been resolved and Commonwealth University is currently reporting on the prescribed schedule Millersville: The Registrar’s Office will evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University’s last date of attendance. Primarily, the frequency of submissions to the NSC.

View Audit 348667

Finding 537424 (2024-006)

Material Weakness 2024

Blackford County Schools

IN

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-006 Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Federal Agency: Department of Education Federal Program: COVID‐19 ‐ Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S42...

FINDING 2024-006 Subject: COVID‐19 ‐ Education Stabilization Fund ‐ Reporting Federal Agency: Department of Education Federal Program: COVID‐19 ‐ Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass‐Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Chad Yencer, Superintendent Contact Phone Number: 765-348-7550 Views of Responsible Official: We concur with this finding Description of Corrective Action Plan: Internal Control 1. For state reporting related to ESSER grants, the Grants/Data Specialist will compile all required information and maintain thorough supporting documentation. The Corporation Treasurer will then review the compiled financial data for the reporting period, verifying its accuracy before presenting it to the Superintendent. Finally, the Superintendent will review the information and supporting documentation, confirming its accuracy prior to submission to the Indiana Department of Education (IDOE). All workpapers and calculations will be recorded and kept for verification Anticipated Completion Date: August 2025

View Audit 348618

Finding 537413 (2024-028)

Significant Deficiency 2024

State of Vermont

VT

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Reference Number: 2024-028 Prior Year Finding: 2023-034 Federal Agency: U.S. Department of Homeland Security State Agency: Department of Public Safety Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: FEM...

Reference Number: 2024-028 Prior Year Finding: 2023-034 Federal Agency: U.S. Department of Homeland Security State Agency: Department of Public Safety Federal Program: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Award Number and Year: FEMA-4474-DR-VT (2020), FEMA-4532-DR-VT (2020), FEMA-4621-DR-VT (2021), FEMA-4695-DR-VT (2023), FEMA-4720-DR-VT (2023) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. The Department should continue to improve its procedures and internal controls to ensure that all required subawards and subaward modifications are reported accurately and timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: Public Safety will continue implementation of its corrective action plan from the prior year. A new procedure will be developed for a periodic review of FFATA entries to add a control step ensuring that all FFATA entries are timely and accurate. A training will also be delivered to Public Assistance staff to ensure that the FFATA entry process is understood in both FSRS and SAM.gov. These corrective actions will be completed by April 4th, 2025 Scheduled Completion Date of Corrective Action Plan: April 4, 2025 Contacts for Corrective Action Plan: Richard Hallenbeck, Director of Administration/Finance richard.hallenbeck@vermont.gov

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