Corrective Action Plans

Finding 526361 (2024-002)

Material Weakness 2024

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

See attached letter that was sent to the DOE on 2/25/25 along with the approval email and documents from DOE. During ESSER II Constmction we had several companies work on projects at Fremont Community Schools. To no one's fault but my own, the Davis-Bacon requirements wore not fully communicated to ...

See attached letter that was sent to the DOE on 2/25/25 along with the approval email and documents from DOE. During ESSER II Constmction we had several companies work on projects at Fremont Community Schools. To no one's fault but my own, the Davis-Bacon requirements wore not fully communicated to these companies. One company that did work for us could not respond with a positive affirmation on Davis-Bacon. Their response is as follows: "We will not be able tQ v.rovide a letter stating we paid our employees a Prevailing Wage (pr work completed at Fremont Community Schools. We do not have any proposals or signed contracts stating these iobs were Prevailing Wage. As such, our employees were not p_aid a Prevailing Wage when working on these proiects. •~ I (Dr. William Stitt) have watched the webinar regarding Davis-Bacon requirements provided by the U.S. Department of Education (USDE) and U.S. Department of Labor (DO1). I have also read through the questions and responses for the December 7, 2023 webinar. I attest that I and Fremont Community Schools commit that applicable Davis-Bacon requfrements will be utilized on any future construction, or construction related, activities using $2,000 or greater of Federal grant funds and will follow Davis-Bacon requirements.

View Audit 345281

Finding 526356 (2024-004)

Significant Deficiency 2024

Saint Louis University

MO

Matching / Level of Effort / Earmarking Student Financial Aid Allowable Costs / Cost Principles

We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. With the financial aid office now ne...

We are in the process of revising our disbursement process to ensure that all Title IV aid disbursements are held until the corresponding aid offer notification has been sent. This will eliminate any timing gaps between the notification process and disbursements. With the financial aid office now near full staffing, we have reinforced training for staff to emphasize the importance of adhering to the revised disbursement timeline. This training includes guidance on managing exceptions and prioritizing compliance in the aid process. While we currently lack the capacity to send aid notifications daily, we are conducting a review of our automated processes to explore solutions for increasing the frequency of aid offer notifications. This may include evaluating potential system enhancements or resource reallocation to support more frequent notifications. We have implemented additional internal monitoring procedures to regularly review the timing of aid offer notifications and disbursements. Any rejected records will be resolved and resubmitted with the same timeframe. This will ensure ongoing compliance and allow for prompt identification and resolution of any discrepancies. The University is committed to maintaining compliance with all federal regulations and ensuring transparency in our financial aid processes. By implementing these corrective actions, we are confident that the risk of future noncompliance has been minimized. Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.

View Audit 345274

Finding 526346 (2024-002)

Material Weakness 2024

Saint Louis University

MO

Eligibility Matching / Level of Effort / Earmarking Student Financial Aid

To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is ac...

To address the conditions identified, we are taking immediate and proactive steps to strengthen our internal controls and processes. These include enhancing staffing capacity, providing additional training, and implementing more robust checks and balances to ensure all verification information is accurately and completely submitted to the CPS. The University has opened multiple positions within the department to enhance efficiency. All current staff will be trained on a continuous basis to ensure knowledge of compliance. We have also engaged an outside consultant to conduct a comprehensive compliance review, ensuring alignment with federal requirements and best practices. Additionally, we are increasing funding for professional development to equip our staff with the skills and knowledge necessary to maintain compliance and ensure the integrity of our processes. Regarding timely submission to CPS, we affirm that all affected students' eligibility was accurately determined, and no Title IV funds were disbursed to ineligible students. We remain committed to maintaining the integrity of the Title IV programs and will take the necessary steps to prevent future occurrences.  Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.

View Audit 345274

Finding 526338 (2024-003)

Material Weakness 2024

Saint Louis University

MO

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. The University has already hired multiple positions and had various training courses...

To address these findings, the University is committed to increasing staffing levels and enhancing training programs to reduce the likelihood of human input errors and ensure the timely resolution of system updates. The University has already hired multiple positions and had various training courses in order to enhance knowledge of compliance. Additionally, we are actively reviewing and revising our internal control procedures, including:  Strengthening review processes to verify the accuracy of enrollment data reported to the NSLDS.  Working with University staff to enhance the functionality of Tableau reports to avoid filtering issues and improve the identification of withdrawn students requiring reporting.  We recognize the importance of accurate and timely reporting to the NSLDS to maintain compliance with program requirements and support the USDE's ability to monitor enrollment status. These corrective actions will help us address the root causes of the issues identified and prevent recurrence in the future.  Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.

View Audit 345274

Finding 526335 (2024-001)

Material Weakness 2024

Saint Louis University

MO

Matching / Level of Effort / Earmarking Student Financial Aid

First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, in...

First, we believe the inaccuracies identified in the academic end date and student year reporting were isolated errors, which have not been a historical issue for the University. Second, the delays in reporting Pell and Federal Direct Loan disbursements to the COD were due to capacity challenges, including staffing shortages that impacted our ability to resolve rejected submissions within the required timeframe.  To address these issues, we are taking proactive steps to strengthen our processes and ensure future compliance. These include efforts to fully staff our team, engaging an outside consulting firm to conduct a compliance and best practices review, and increasing funding for professional development to enhance staff expertise and efficiency.  Additionally, the University is working with external consultants to enhance financial aid processing systems. This will gain efficiencies to ensure data is reported within the required timeframes. We remain confident in the overall accuracy and integrity of our processes and are committed to implementing improvements to ensure timely and accurate reporting to the COD moving forward.  Alex DeLonis, Assistant Vice President for Student Financial Services, is responsible for addressing the above item by May 2025.

View Audit 345274

Finding 526334 (2024-002)

Significant Deficiency 2024

Greenfield Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2024-002 Corrective Action Plan: An internal review of our process for reporting Pell payments to Common Origination & Disbursement (COD) reveals that the vast majority of Pell payments are reported within 2 business of disbursement. The Pell payment in question was disbursed two wee...

Finding number: 2024-002 Corrective Action Plan: An internal review of our process for reporting Pell payments to Common Origination & Disbursement (COD) reveals that the vast majority of Pell payments are reported within 2 business of disbursement. The Pell payment in question was disbursed two weeks after our scheduled fall disbursement and reported to COD 12 and 13 days late. The disbursement occurred once the student completed all outstanding financial aid requirements. The procedures for reporting all Title IV payments and disbursements to COD has been reviewed with the staff members responsible for transmitting origination and disbursement records to COD. Procedures have been developed to more readily identify financial aid disbursements that take place outside of the established disbursement date for the term. This corrective action plan was put into place in February 2024. Finding 2024-02 occurred prior to the action plan’s implementation. Timeline for Implementation of Corrective Action Plan: February 2024 Contact Person Mark Boudreau, Comptroller

View Audit 345265

Finding 526332 (2024-001)

Significant Deficiency 2024

Greenfield Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2024-001 Corrective Action Plan: To ensure that the college is using the same effective date for (unofficial) withdrawal on both the R2T4 calculations and for reporting unofficial withdrawal enrollment changes to NSLDS, the financial aid office will forward the list of students who a...

Finding number: 2024-001 Corrective Action Plan: To ensure that the college is using the same effective date for (unofficial) withdrawal on both the R2T4 calculations and for reporting unofficial withdrawal enrollment changes to NSLDS, the financial aid office will forward the list of students who are determined to have unofficially withdrawn and their associated date of unofficial withdrawal to the registrar's office at the end of each term. The registrar's office will then adjust all students' records in their SIS (Banner) as needed prior to submitting their report to NSC/NSLDS. This corrective action plan was finalized in June 2024. Finding 2024-01 occurred prior to the action plan’s implementation. Timeline for Implementation of Corrective Action Plan: June 2024 Contact Person Mark Boudreau, Comptroller

View Audit 345265

Finding 526243 (2024-011)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

Responsible Contact Person(s): Mike Jones, Chief Information Officer Corrective Action Planned: Language has been added to the Conduent contract renewal for option years 1 and 2 to require the SOC 1 Type II. The renewal is in the process of being reviewed and executed to go into effect July 1, 2025...

Responsible Contact Person(s): Mike Jones, Chief Information Officer Corrective Action Planned: Language has been added to the Conduent contract renewal for option years 1 and 2 to require the SOC 1 Type II. The renewal is in the process of being reviewed and executed to go into effect July 1, 2025. Language added to contract renewal: Contractor Internal Controls Reports The Contractor shall provide the Department, at a minimum; annual, unredacted reports from its independent external auditor on the effectiveness of the Contractor’s internal controls conducted in accordance with the AICPA Statement on Standards for Attestation Engagements. If the reports disclose deficiencies in internal controls, the Contractor shall include management’s corrective action plans to remediate the deficiency. The Contractor shall provide the following reports: · SOC 1 Type 2 Report that reports on the controls at the service organization which are relevant to the user entities’ internal control over financial reporting · SOC 2 Type 2 Report covering all five Trust Services Criteria (Security, Availability, Processing Integrity, Privacy and Confidentiality) The contractor shall provide the Department with these internal control reports within 30 days of the report’s issue date. Reports shall cover a period of 12 months beginning from the end date of the prior audit period with the first report covering a period of 12 months from the execution date of this contract. The contractor shall provide unredacted SOC 1 Type 2 and/or SOC 2 Type 2 reports as described above for any subservice organizations which provide a service to the Contractor that may impact the Department’s financial, program operations, or data security as determined by the Department. Estimated Completion Date: 7/1/2026

View Audit 345214

Finding 526237 (2024-104)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additio...

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additionally, DSS will create a systems modification request to correct errors that are identified as occurring as a result of inaccurate programming in the data modification phase of federal report creation. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526226 (2024-106)

Significant Deficiency 2024

Commonwealth of Virginia

VA

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

Responsible Contact Person(s): Ida Witherspoon, Chief Financial Officer Corrective Action Planned: Send periodic e-mail reminders to program staff responsible for submitting FFATA data to the Federal Reporting Unit for submission to the federal government. Estimated Completion Date: 3/15/2025

View Audit 345214

Finding 526224 (2024-102)

Significant Deficiency 2024

Commonwealth of Virginia

VA

HUD Housing Programs Reporting Significant Deficiency § 200.303

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additio...

Responsible Contact Person(s): Angela Morse, Director of Benefit Programs Frank Smith, Associate Director of Benefit Programs Corrective Action Planned: DSS will perform an analysis of identified reporting errors to determine causality and the appropriate actions to resolve reporting errors. Additionally, DSS will create a systems modification request to correct errors that are identified as occurring as a result of inaccurate programming in the data modification phase of federal report creation. Benefit Program is working with appropriate parties to resolve outstanding errors. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 526181 (2024-099)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Student Financial Aid Cash Management Significant Deficiency

Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Linsha Xie, Controller Corrective Action Planned: Step 1: The Financial Aid Office and Controller's Office will jointly review the current reconciliation process for federal assistance programs. This will include identifying ...

Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Linsha Xie, Controller Corrective Action Planned: Step 1: The Financial Aid Office and Controller's Office will jointly review the current reconciliation process for federal assistance programs. This will include identifying all steps involved in the reconciliation process, documenting the roles and responsibilities of each office, and pin pointing areas where communication breakdowns have occurred in the past. Step 2: Based on the review, the offices will enhance the reconciliation procedures to address identified weaknesses. This will include developing standardized templates for reconciliations, establishing clear timelines for each step of the process, defining specific procedures for investigating and resolving reconciling differences, and implementing a system of checks and balances to ensure accuracy. Step 3: Formalize communication protocols between the Financial Aid Office and the Controller's Office to facilitate timely and effective information sharing related to federal assistance programs. This will include designated points of contact in each office, regular meetings and reminders for discussing reconciliation issues, and a shared folder for archiving reconciliation working paper and supporting documents. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 526179 (2024-097)

Significant Deficiency 2024

Commonwealth of Virginia

VA

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

Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the Direct Loan Notification Process will be sent out timely to all students with Direct Loan disbursements. Additional personnel have been named back-up to...

Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the Direct Loan Notification Process will be sent out timely to all students with Direct Loan disbursements. Additional personnel have been named back-up to ensure notifications are submitted timely. The Student Accounts Office will notify the NSU department via email when disbursement of aid occurs. Calendar notifications can be created to ensure notifications are sent out timely. Estimated Completion Date: 8/31/2025

View Audit 345214

Finding 526161 (2024-090)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Student Financial Aid Reporting Subrecipient Monitoring

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: George Mason will implement the following plan of action: - Management will enhance its communications relating to enrollment reporting in the Registrar and Financial Aid Offices. - Implem...

GMU Responsible Contact Person(s): Alethia Shipman, Director, Student Financial Aid Corrective Action Planned: George Mason will implement the following plan of action: - Management will enhance its communications relating to enrollment reporting in the Registrar and Financial Aid Offices. - Implement corrective actions to ensure that the University reports accurate and timely student enrollment status changes to the National Student Loan Data System. - Management will consider implementing a quality control review process to monitor the accuracy of campus and program-level batch submissions, such as implementing regularly scheduled self-audits of NSC data. Estimated Completion Date: 12/31/2025 NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: The University has developed detailed procedures to improve reporting to NSLDS. These procedures include reviewing and updating Colleague system processing, designating staff members in both the Registrar and Financial Aid Offices to process, review and resolve reporting issues, and continued monitoring and verification of reports transmitted to NSLDS from the National Student Clearinghouse. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Angelique Robinson, College Registrar Zina Jemison, Associate College Registrar Corrective Action Planned: Step 1: College Registrar (CR) and Associate College Registrar (ACR) will review National Student Loan Data System trainings, documentation, and initiate training sessions with appropriate NSLDS staff to answer any outstanding questions about the system. Step 2: CR and ACR will review important NSLDS deadlines and incorporate lessons learned from the trainings to set the tone for internal deadline processing changes so that the semi-automated graduation process can be performed in a faster manner. The CR and ACR will also determine which additional team members within the College Records Office will assist in the completion of record updating and reporting requirements within NSLDS, outlining the specific tasks that will need to be done by each participating member and the information system queries that will be used for internal auditing purposes. Step 3: CR and ACR will consult with Financial Aid staff to finalize new internal record adjustment processing deadlines to ensure that the changes in procedures are made in a timely manner and in support of Financial Aid processes. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Carrie John, University Registrar Corrective Action Planned: The University is taking corrective action to ensure accurate and timely reporting of student enrollment changes to NSLDS. Corrective actions include enhancing procedures, providing additional training, and improving internal reviews. Estimated Completion Date: 6/30/2026 RU Responsible Contact Person(s): Katie Piper, Registrar Corrective Action Planned: The Registrar's Office has met and completed initial planning and timelines to address procedural changes needed to report the loan data timely. Estimated Completion Date: 12/31/2025 UVA Responsible Contact Person(s): Steve Kimata, Associate Vice President for Enrollment and University Registrar Corrective Action Planned: The University will implement additional controls to ensure the accuracy and timeliness of enrollment data reported to NSLDS. This includes working collaboratively with Student Financial Services and Information Technology Services to monitor and report late withdrawals, review and update the information system process for creating enrollment files, and implement a quality control review to check student status change batches for accuracy and timeliness. Estimated Completion Date: 6/30/2025 VSU Responsible Contact Person(s): Nedra Jones, University Registrar Corrective Action Planned: 1) VSU has implemented an automated alert system to notify staff of upcoming reporting deadlines, cross-referenced information system data with the SCHEV Degree Inventory Report, and are actively collaborating with SCHEV to resolve discrepancies. These items are complete. 2) Additionally, VSU is in the process of implementing the following additional corrective actions: A.) A comprehensive review of current enrollment reporting processes; B.) Closer collaboration with VSU third-party service provider to streamline and improve the enrollment reporting; C.) Designating an individual within the Registrar's Office to oversee National Student Clearinghouse (NSC) and NSLDS reporting duties; and D.) establishing a quality control process to include monthly random sample audits of enrollment data. Additionally, VSU will reconcile student addresses between the information system and NSLDS for Federal Direct Loan borrowers. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526136 (2024-096)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Student Financial Aid Reporting Significant Deficiency

Responsible Contact Person(s): Brad Barnett, Director, University Scholarships and Financial Aid Corrective Action Planned: Implement a "direct loan posting date audit report procedure," which outlines how posting dates in the management application are compared to posting dates in the system. Also ...

Responsible Contact Person(s): Brad Barnett, Director, University Scholarships and Financial Aid Corrective Action Planned: Implement a "direct loan posting date audit report procedure," which outlines how posting dates in the management application are compared to posting dates in the system. Also add a checklist item to the monthly reconciliation to confirm the new procedure is being followed. Estimated Completion Date: 4/1/2025

View Audit 345214

Finding 526133 (2024-093)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Student Financial Aid Reporting Significant Deficiency

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the unearned funds for students will be sent to COD timely. NSU will ensure that all files are submitted timely so that this will not be a future issue....

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office will ensure that the unearned funds for students will be sent to COD timely. NSU will ensure that all files are submitted timely so that this will not be a future issue. A reinforcement of procedures for exporting disbursements and staff training will be maintained as well as ensuring that a back-up staff member is in place. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Linsha Xie, Controller Corrective Action Planned: Step 1: Establish clear and documented communication protocols between the Financial Aid Office and the Controller's Office regarding student withdrawals and the return of unearned Title IV funds. This will include designated points of contact in each office, a standardized process for the Financial Aid Office to notify the Controller's Office of requiring a return of Title IV funds, confirming the return by the Controller’s Office, and regular meetings between the two offices to review procedures and address any issues. Step 2: Develop a written policy and procedure. This will include step-by-step instructions for processing the return of funds, including required documentation and timelines, Clear delineation of responsibilities between the Financial Aid Office and the Controller's Office, and contingency plans for staff turnover or absences. Step 3: Conduct periodic reviews and reconciliation of returned Title IV funds to ensure accuracy and timeliness. This will include reconciling returned funds with ED records and identifying any discrepancies or delays in the return of unearned funds. Estimated Completion Date: 6/30/2025 ODU Responsible Contact Person(s): Vera Riddick, Director of Financial Aid Corrective Action Planned: The University is taking corrective action to improve processes to ensure data accuracy and compliance with reporting requirements. Corrective actions include utilizing system functionality and enhancing Office of Student Financial Aid procedures. Differences totaling $325 that were identified during the audit have been returned to the Department of Education. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526132 (2024-092)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Student Financial Aid Special Tests & Provisions Significant Deficiency

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has created a Certification Form of Countable Days in a Semester that is required to be signed off by the Director of Financial Aid, Associate Director of Financial Aid (...

NSU Responsible Contact Person(s): Carla L. Dailey, Director of Financial Aid Corrective Action Planned: NSU Financial Aid Office has created a Certification Form of Countable Days in a Semester that is required to be signed off by the Director of Financial Aid, Associate Director of Financial Aid (Return of TIV Coordinator) and the University Registrar prior to the start of each semester. This process will be included in the annual financial aid set up process. Estimated Completion Date: 8/31/2025 NVCC Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Corrective Action Planned: Step 1: Ensure proper setup of academic and holiday calendars in the information system. This will include the Director of Financial Aid working closely with the Policy Planning Specialist to ensure the academic calendar and holiday calendars are set up properly in the information system to account for all breaks. Step 2: Improved communications during calendar and information system setups. This will include regular scheduled meetings between the Policy Planning Specialist, Associate Director of Financial Aid Information Systems, and the Director of Financial Aid to review the academic and holiday calendar setups in the information system. Make any appropriate updates to the academic calendar and financial aid setups in the information system. Step 3: Run VCCS Custom R2T4 Report and perform R2T4 calculations/adjustments based on the R2T4 policies and procedures. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 526130 (2024-089)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Internal Control / Segregation of Duties Subrecipient Monitoring Significant Deficiency § 200.303

Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Lisa Boyko, Associate Director of Financial Aid Corrective Action Planned: Step 1: Develop a timeline to review information system Access for college financial aid staff and non-financial aid staff with financial aid access. ...

Responsible Contact Person(s): Sherika Charity, Director of Financial Aid Lisa Boyko, Associate Director of Financial Aid Corrective Action Planned: Step 1: Develop a timeline to review information system Access for college financial aid staff and non-financial aid staff with financial aid access. This will include the Director of Financial Aid and the Associate Director of Financial Aid Information Systems who will set scheduled meetings to conduct periodic reviews of the information system Access each semester using a designated report. Step 2: The Associate Director of Financial Aid Information Systems will create a repository to store the designated reports, which will be accessible by the Director of Financial Aid. Step 3: The Director of Financial Aid and the Associate Director of Financial Aid Information Systems will review access. If changes are needed, the appropriate IT forms will be submitted to have staff members access updated appropriately. Estimated Completion Date: 6/30/2025

View Audit 345214

Finding 526123 (2024-010)

Significant Deficiency 2024

Commonwealth of Virginia

VA

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

Responsible Contact Person(s): Kevin Platea, Chief Information Officer Corrective Action Planned: DSS has 15 plus applications that are in active oversight, IT Business Administration is in receipt of the required SOC 2, Type 2 reports. However, additional requirements to capture the SOC 1, Type 2 ...

Responsible Contact Person(s): Kevin Platea, Chief Information Officer Corrective Action Planned: DSS has 15 plus applications that are in active oversight, IT Business Administration is in receipt of the required SOC 2, Type 2 reports. However, additional requirements to capture the SOC 1, Type 2 reports has not yet been accomplished. Estimated Completion Date: 12/31/2025

View Audit 345214

Finding 526117 (2024-003)

Material Weakness 2024

Frontier School Corporation

IN

Questioned Costs School Nutrition Programs Internal Control / Segregation of Duties § 200.303

Context: We noted that for two claims in a sample of four, the Food Service Director prepared the reimbursement claim without a secondary, documented review to ensure the accuracy of the reimbursement claim. Additionally, the number of meals claimed on two of the four claims sampled did not agree...

Context: We noted that for two claims in a sample of four, the Food Service Director prepared the reimbursement claim without a secondary, documented review to ensure the accuracy of the reimbursement claim. Additionally, the number of meals claimed on two of the four claims sampled did not agree to the supporting meal system reports. There was a gross overstatement of meals claimed of $349 and a gross understatement of meals claimed of $161 resulting in a net over reimbursement amount of $188. Contact Person Responsible for Corrective Action: Steve Boulanger, Food Service Director Contact Phone Number: 765-240-2372 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As of February 2024, the Food Service Director prepares the claim for reimbursement, and the Corporation Treasurer double checks all numbers and signs the claim. Anticipated Completion Date: 02/01/2024

View Audit 345211 Questioned Costs: $1

Finding 526114 (2024-002)

Material Weakness 2024

Frontier School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guide...

Context: During testing over controls for eligibility, we noted there was no formal, secondary review for the applications entered in the food service software determining eligibility. Additionally, there was no documented annual review by School Corporation personnel of the income eligibility guidelines used by the food service software. Contact Person Responsible for Corrective Action: Steve Boulanger, Food Service Director Contact Phone Number: 765-240-2372 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As of February 2024, our new Food Service Director has implemented a second check of all applications by the High School ECA Treasurer. Additionally, the Food Service Director will print the USDA income parameters after July 1st, compare it to the income guidelines in our nutrition software, and have the High School ECA Treasurer double check the numbers as well. Both employees will sign off on the form, and it will be filed for audit purposes. Anticipated Completion Date: 07/01/2025

View Audit 345211

Finding 526003 (2024-004)

Material Weakness 2024

Weld County School District Re-8

CO

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility § 200.303

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555 and 10.559 Recommendation: We recommend the District retain all direct certification reports from the State and for the District to review applications submitted electronically through food service system to determine correct eligibili...

Child Nutrition Cluster – Assistance Listing No. 10.553, 10.555 and 10.559 Recommendation: We recommend the District retain all direct certification reports from the State and for the District to review applications submitted electronically through food service system to determine correct eligibility determination is made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Direct Cert files received from the State starting in August 2024 will be kept on the Food Service Google drive. Names of the contact persons responsible for corrective action: Wesley Haselhorst and Dawn Koshio Planned completion date for corrective action plan: June 30, 2025

View Audit 345145

Finding 525985 (2024-002)

None 2024

City of St Petersburg, Florida

FL

Internal Control / Segregation of Duties Special Tests & Provisions Matching / Level of Effort / Earmarking

No corrective action plan is required.

View Audit 345139

Finding 525976 (2024-002)

None 2024

Converse University

SC

Student Financial Aid Subrecipient Monitoring Reporting

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, ...

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, accurately or timely. Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.038, 84.063, 84.268 Corrective Action Plan The finding was due to a lack of a process to correctly backdate administrative withdrawals when a student receives a "W" grade after the withdrawal deadline. This inconsistency led to inaccurate reporting to the National Student Loan Data System (NSLDS) and the academic file. To address this, management has collaborated with the Offices of Campus Technology, Student Financial Services, and the Registrar and has developed and implemented better procedures for handling administrative withdrawals. These procedures will ensure: • Consistent reporting of withdrawal dates to NSLDS. • Ensuring that withdrawal dates are recorded uniformly in both the Registrar’s office and Student Financial Services. • Accurate assignment of "W" grades according to the academic calendar. These new procedures were implemented in the beginning of 2024. The Registrar’s office will continue to submit regular enrollment reports to NSLDS, promptly reporting any changes to student enrollment as required. The Office of the Registrar will be responsible for implementing the corrective action plan, under the supervision of the University Registrar and Director of Institutional Research and Effectiveness. Shannon Bishop Shannon.bishop@converse.edu University Registrar

View Audit 345135

Finding 525914 (2024-001)

Significant Deficiency 2024

Indian Center Housing Corporation

NE

Questioned Costs Internal Control / Segregation of Duties Student Financial Aid

The corrective action plan for the internal controls over expenses paid (2024-001), is summarized as follows: Corrective Action Planned: The Center will review and update its procedures to ensure the proper payment of allowable expenses. Anticipated Completion Date: December 31, 2024. Responsible: M...

The corrective action plan for the internal controls over expenses paid (2024-001), is summarized as follows: Corrective Action Planned: The Center will review and update its procedures to ensure the proper payment of allowable expenses. Anticipated Completion Date: December 31, 2024. Responsible: Management and Board of Directors.

View Audit 345073 Questioned Costs: $1

Corrective Action Plans

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