Corrective Action Plans

Finding 519012 (2024-001)

Significant Deficiency 2024

MN

Eligibility Matching / Level of Effort / Earmarking Significant Deficiency § 200.303

2024-001 Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2024 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action: • Scanning Applications: o CSFP staff scan applications daily. These ...

2024-001 Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2024 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action: • Scanning Applications: o CSFP staff scan applications daily. These applications are then stored in SharePoint. We have 2-3 volunteers weekly who rename applications based on Client ID, Name, and Expiration Date, then file them electronically based on their expiration date. This ensures that we are always up to date on having an electronic version of our CSFP applications. o Before shredding any applications that have been scanned, we confirm that the application exists in the system (done by CSFP staff). • If an application is missing: o Confirm that application information is in ClientTrack and document through a generated printed application. o Send application to distribution site for next distribution, to ensure participant signs new application before they receive another CSFP box. Anticipated Completion Date: This process was fully implemented at the end of May 2024. It should be noted that applications have a 3-year certification period, so the full effect of the new process won’t be realized until spring of 2027. Contact: Dan Fuhrman, Controller Second Harvest Heartland 7101 Winnetka Ave N Brooklyn Park, MN 55428 651-209-7901 651-484-1064 (fax)

View Audit 337506

Finding 518996 (2024-001)

Significant Deficiency 2024

Mizpah Assisted Living Services, INC

MO

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

Section 232 Insured Mortgage Note Payable– Assistance Listing No. 14.129 Recommendation: We recommend review of controls to include processes to ensure timely submission of quarterly financial reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the a...

Section 232 Insured Mortgage Note Payable– Assistance Listing No. 14.129 Recommendation: We recommend review of controls to include processes to ensure timely submission of quarterly financial reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Submissions have been made and controls will be reviewed to ensure timely submissions in the future. Name(s) of the contact person(s) responsible for corrective action: Joe Girardi, CFO Planned completion date for corrective action plan: November 2024

View Audit 337480

Finding 518991 (2024-001)

Material Weakness 2024

Ahepa 78 Phase Vi, Inc.

IN

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

Management agrees with the finding and the funds were promptly repaid within the same month.

View Audit 337450

Finding 518982 (2024-001)

Significant Deficiency 2024

Mascoutah Community Unit School District No 19

IL

Matching / Level of Effort / Earmarking Special Tests & Provisions

Condition: The District did not receive the weekly certified pays for the construction project that was partially funded by Impact Aid construction funds. Recommendation: We recommend that school officials review the grant requirements for all of the federal grants that they receive. Managemen...

Condition: The District did not receive the weekly certified pays for the construction project that was partially funded by Impact Aid construction funds. Recommendation: We recommend that school officials review the grant requirements for all of the federal grants that they receive. Management Response: Management will request weekly certified payroll and a statement of compliance from all contractors working on construction projects to ensure that prevailing wages are being paid on the project. Anticipated Date of Completion: June 30, 2025

View Audit 337446

Finding 518961 (2024-001)

None 2024

Northern Tier Career Center

PA

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

Corrective Action Plan December 19, 2024 Federal Audit Clearinghouse Northern Tier Career Center respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: EFPR Group, CPAs, PLLC Certified Public Accountants ...

Corrective Action Plan December 19, 2024 Federal Audit Clearinghouse Northern Tier Career Center respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: EFPR Group, CPAs, PLLC Certified Public Accountants 8 Denison Parkway East Corning, NY 14830 Audit period: July 1, 2023 – June 30, 2024 The findings from the June 30, 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 PROGRAM AUDIT FINDING 2024-001 – Student Financial Aid Cluster – Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.286 and 84.063; Grant Period - For the year ended June 30, 2024 Condition: The School does not have a written information security program containing the required minimum elements including the designation of a qualified individual who is responsible for implementing and monitoring the School’s program. Criteria: The School is required to have a written information security program that includes the required minimum elements including designating a qualified individual who is responsible for implementing and monitoring the School’s program. Cause: The School did not have a written information security program containing the required elements. Effect of Condition: The School was not in compliance with the requirement to have a written information security program that includes the required minimum elements including designating a qualified individual who is responsible for implementing and monitoring the School's program Questioned Costs: None. Recommendation: The School should designate a qualified individual responsible for implementing an monitoring the School's information security program. This individual should put procedures in place to create a written information security program that addresses the required minimum elements required by the Student Financial Aid cluster included in the Gramm-Leach-Bliley Act - Student Information Security. Views of Responsible Officials and Planned Corrective Actions: NTCC is in the process of a First Reading Policy on or before February 20, 2025, and a Second Reading Policy for full approval on or before March 20, 2025. This policy will name the Practical Nursing Coordinator, as the individual responsible for implementing and monitoring the School’s security program. The seven required minimum elements for a financial institution of fewer than 5,000 customers will be in place with this policy. Contact Person Responsible for Corrective Action: Colleen Edsell, Business Administrator. Anticipated Completion Date: The corrective action plan will be completed by March 20, 2025. If the Federal Audit Clearinghouse has questions regarding this plan, please call Colleen Edsell at 570-265-8111. Sincerely yours, Gary Martell, Director

View Audit 337404

Finding 518849 (2024-001)

Material Weakness 2024

William Jessup University

CA

Student Financial Aid Reporting Material Weakness

Untimely and Inaccurate Returns of Title IV Funds (R2T4) and National Student Loan Data System Updates (NSLDS) Planned Corrective Action: We will provide additional training to financial aid staff on Return to Title IV (R2T4) processing from a third party servicer with expertise in processing with o...

Untimely and Inaccurate Returns of Title IV Funds (R2T4) and National Student Loan Data System Updates (NSLDS) Planned Corrective Action: We will provide additional training to financial aid staff on Return to Title IV (R2T4) processing from a third party servicer with expertise in processing with our current financial aid management system. We will also collaborate with the Registrar’s Office to implement a system that ensures timely notification of student withdrawals, enabling the financial aid office to process R2T4 returns within the required timeframe. We will establish more robust internal controls to verify that withdrawals are correctly updated in NSLDS, and review staffing needs to ensure adequate resources for processing Title IV aid returns efficiently. Person Responsible for Corrective Action Plan: Deborah Rezene, Associate Vice President of Student Financial Services Anticipated Date of Completion: 1/3/2025

View Audit 337234

Finding 518703 (2024-002)

Significant Deficiency 2024

Mt. Hood Community College

OR

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2024-002 Federal Agency Name: U.S. Department of Education Pass-Through Entity: n/a Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Program Name: Student Financial Assistance (SFA) Cluster Finding Summary: In auditor testing of 60 samples, 9 students did not receive a timely noti...

Finding 2024-002 Federal Agency Name: U.S. Department of Education Pass-Through Entity: n/a Assistance Listing Number: 84.007, 84.033, 84.063, 84.268 Program Name: Student Financial Assistance (SFA) Cluster Finding Summary: In auditor testing of 60 samples, 9 students did not receive a timely notification of their award from the College Corrective Action Plan: The Director of Financial Aid will implement procedures to ensure timely notification of financial aid awards: • In August 2024, the Director collaborated with IT to fix a notification system glitch. • IT added a control that sends an email alert to IT, the Director, and tech support if there is a mismatch between student IDs for loan disbursement and notifications sent. This ensures immediate review and resolution of any missed notifications. Responsible Individual(s): Christopher Natelborg, Director of Financial Aid Anticipated Completion Date: February 2025.

View Audit 337161

Finding 518594 (2024-002)

Significant Deficiency 2024

Gaston County

NC

Questioned Costs Matching / Level of Effort / Earmarking Significant Deficiency § 200.516

Finding: 2024-002 Name of Contact Person: Michael Coone, Assistant Social Services Director Criteria: In accordance with 20 CFR 681.590, local youth programs must expend not less than 20 percent of the funds allocated to them, except for the local area expenditures for administration, to provide pai...

Finding: 2024-002 Name of Contact Person: Michael Coone, Assistant Social Services Director Criteria: In accordance with 20 CFR 681.590, local youth programs must expend not less than 20 percent of the funds allocated to them, except for the local area expenditures for administration, to provide paid and unpaid work experiences. Recommendation: Require the County Program Directors to implement procedures to ensure that earmarking requirements are met. Corrective Action/Management’s Response: Management concurs with this finding and will adhere to the Corrective Action Plan in this audit report. The County has implemented the following process: Gaston County Workforce Development Board staff worked closely with the previous Youth service provider requesting them to assign 100% of their WEX specialist salary towards work-based learning expenses to obtain this goal. With a new service provider, Two Hawk Employment Services, their financial staff have budgeted 20% of all WEX related activities, salaries, staff costs, participant costs, etc. to meet the 20% goal. Gaston County WDB and Two Hawk Employment Services have adjusted staff day sheet logs to reflect 20% of staff activities to ensure all staff are assigning the work appropriately. The Gaston County Workforce Development Board mandated in the service provider Youth contract to meet the 20% WEX Expenditure and future contract awards are determined on successfully meeting the expenditure requirement. Per the state’s most recent Youth Expenditure Report at the end of October 2024, Gaston County Workforce Development Board is 76% towards meeting the goal. The Workforce Development Board staff and management will continue to monitor monthly that 20% of all salaries and WEX activities are accurately reflected on all invoices and financials from Two Hawk Employment Services. Proposed Completion Date: Management and the Board will implement the above procedures immediately with a completion date of June 30, 2025.

View Audit 337042 Questioned Costs: $1

Finding 518570 (2024-004)

Significant Deficiency 2024

Washington County Board of Education

MD

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Finding Number: 2024-004 Prior Year Finding: No Federal Agency: US Department of Education Federal Program: Eduation Stabilization Fund Assistance Listing: 84.425 Pass-Through Entity: Maryland Statement Department of Education Pass-Through Award Number and Period: 211935 3/24/21 - 9/30/23 Complianc...

Finding Number: 2024-004 Prior Year Finding: No Federal Agency: US Department of Education Federal Program: Eduation Stabilization Fund Assistance Listing: 84.425 Pass-Through Entity: Maryland Statement Department of Education Pass-Through Award Number and Period: 211935 3/24/21 - 9/30/23 Compliance Requirement: Davis-Bacon Act Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Recommendation We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, we will start recording on a spreadsheet the Contract number and weeks covered for certified payrolls we receive that falls under the Davis-Bacon Act. This spreadsheet will have an approval column and date column to document our monitoring procedures for tracking and audit purposes. Name(s) of the contact person(s) responsible for corrective action: Adam Pelc, Supervisor of Accounting and Rob Rollins, Director of Facilities Planned completion date for corrective action plan: For immediate implementation and ongoing.

View Audit 337011

Finding 518507 (2024-001)

Significant Deficiency 2024

Odessa College District

TX

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2024-001 Significant Deficiency in Internal Control over Compliance and Other Matters Odessa College will implement the following to ensure compliance with federal regulations, improve internal processes, and prevent future occurrences. Additionally, the college is moving forward with compr...

Finding 2024-001 Significant Deficiency in Internal Control over Compliance and Other Matters Odessa College will implement the following to ensure compliance with federal regulations, improve internal processes, and prevent future occurrences. Additionally, the college is moving forward with comprehensive financial aid advisory services with Ellucian, the College’s enterprise student information system. The engagement/advisory priorities include establishing an R2T4 Process that complies with the 45-day reporting requirement. The engagement period is contracted for the next 14 months. Review and Update Withdrawal Procedures:  Conduct a comprehensive review of current student withdrawal procedures to identify any weaknesses or delays in processing withdrawal dates and the return of Title IV funds.  Ensure that the withdrawal process is thoroughly documented, and that all departments (registrar, financial aid, student accounts) are aligned on their responsibilities related to withdrawal processing. Strengthen Communication between Departments:  Establish a clear communication protocol among the registrar’s office, financial aid office, and student accounts to ensure that withdrawals are processed promptly.  Designate specific individuals to monitor the return of Title IV funds and ensure deadlines are met.  Implement an internal checklist for verifying that all Title IV funds are returned within the required time frame. Implement a Monitoring System:  Set up an automated system or a shared calendar to track Title IV refund timelines for students who withdraw.  Use alerts or reminders to notify responsible staff members when a Title IV refund is due to be returned within the 45-day window.  Monitor and document all returns of Title IV funds to maintain compliance. Staff Training:  Conduct training for staff involved in student withdrawals, financial aid, and compliance to ensure they are knowledgeable about the 45-day return requirement and the importance of adhering to it.  Include a review of the audit finding and corrective actions during departmental Develop a Compliance Audit Checklist:  Create a detailed audit checklist for Title IV refund procedures to be used in periodic internal audits to ensure that all financial aid disbursements, returns, and related processes comply with federal regulations.  Review the checklist regularly to ensure the process is effective and compliant with regulatory changes. Monitoring and Reporting:  Schedule and conduct regular internal audits of Title IV funds return procedures and withdrawal processes to ensure ongoing compliance.  Review audit findings, staff performance, and timelines to identify potential areas for improvement. Compliance Reporting:  Prepare a report for the administrative team outlining corrective actions taken, including the return of funds, updated procedures, and staff training. Responsible Officials: Kim McKay – Vice President Student Services Anticipated Date of Completion: May 2025 meetings to reinforce the importance of compliance.

View Audit 336963

Finding 518503 (2024-003)

Significant Deficiency 2024

South Suburban College - Community College District #510

IL

Questioned Costs Special Tests & Provisions Student Financial Aid

FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures to ensure file documentation would identify student...

FINDING 2024-003 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The College accepts this finding and has implemented the corrective plan below to reinforce established policies and procedures to ensure file documentation would identify students in the return funds population. Plan: South Suburban College established a control process to assist with remaining in compliance as stated in the Single Audit Report Finding 2023-003 Corrective Plan. South Suburban College’s Financial Aid Department used Information Technology reports to retrieve the college’s Return of Title IV funding (R2T4) population, it was found that the reporting files were incorrect. Therefore, the Director of Financial Aid, Financial Manager will review the student population list provided by IT to ensure the population consist of financial aid eligible students who withdrew from all enrolled courses. The Director of Financial Aid will continue to work with the Information Technology Department to enhance the retrieval of the Return of Title IV funding student populations reporting process through Ellucian Colleague per the 2023 Correction Plan.

View Audit 336959 Questioned Costs: $1

Finding 518499 (2024-002)

Significant Deficiency 2024

South Suburban College - Community College District #510

IL

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

FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The college accepts this finding and has implemented the corrective plan below. The error was remedied by correcting the enrollment dates in the Colleague student information syst...

FINDING 2024-002 – CONTROLS AND NONCOMPLIANCE OVER SPECIAL TESTS AND PROVISIONS – RETURN OF FUNDS Management’s Response: The college accepts this finding and has implemented the corrective plan below. The error was remedied by correcting the enrollment dates in the Colleague student information system. Plan: South Suburban College has and will continue to review procedures to identify areas of improvement for attendance reporting to ensure funds are returned accurately and timely. Enrollment dates will be confirmed and entered in the Colleague system prior to the start of academic year by the Financial Aid Director and Financial Aid Manager to support accurate return of funds calculations. This corrective plan has been implemented. Anticipated Date of Completion: 1/31/2025 Name of Contact Person: Yolanda Freemon

View Audit 336959

Finding 518479 (2024-001)

Material Weakness 2024

Dublin City School District

OH

Eligibility School Nutrition Programs Matching / Level of Effort / Earmarking

All electronic free and reduced meal applications are completed by parents/guardians in PaySchools. Since PaySchools does not currently have a SOC1 for Ohio, all applications will be sent to a pending folder. Aramark will ensure all applications are reported correctly in the PaySchools system. Th...

All electronic free and reduced meal applications are completed by parents/guardians in PaySchools. Since PaySchools does not currently have a SOC1 for Ohio, all applications will be sent to a pending folder. Aramark will ensure all applications are reported correctly in the PaySchools system. They began this process 11/25/2024. Because this process started mid-year, Treasurer Office personnel will review all of the approved applications prior to 11/25/2024.

View Audit 336939

Finding 518476 (2024-002)

None 2024

Trinity Bible College and Graduate School

ND

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

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The Financial Aid Office will include weekends in the break days identified in the Return to Title IV schedules created on the COD.gov site. All federal aid will be included in R2T4 calculations. These two issues which came out in...

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The Financial Aid Office will include weekends in the break days identified in the Return to Title IV schedules created on the COD.gov site. All federal aid will be included in R2T4 calculations. These two issues which came out in the audit were resolved and implemented before the fall 2024 semester. Another person will review the R2T4 form before the process is finalized. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 08/15/2024

View Audit 336933

Finding 518475 (2024-001)

Significant Deficiency 2024

Trinity Bible College and Graduate School

ND

Questioned Costs Eligibility Student Financial Aid

Ineligible Disbursements Planned Corrective Action: The Financial Aid Office will review the credit hours earned for each student to ensure the federal loan amounts awarded are appropriate for the number of hours the student earned. This will be done before the beginning of each semester and after f...

Ineligible Disbursements Planned Corrective Action: The Financial Aid Office will review the credit hours earned for each student to ensure the federal loan amounts awarded are appropriate for the number of hours the student earned. This will be done before the beginning of each semester and after final grades have been posted. Person Responsible for Corrective Action Plan: Wes Brothers, Financial Aid Director Anticipated Date of Completion: 12/9/2024

View Audit 336933 Questioned Costs: $1

Finding 518466 (2024-001)

Significant Deficiency 2024

Volunteers of America Chesapeake & Carolinas, INC

MD

Questioned Costs Program Income Cash Management § 200.307 § 200.80

Finding #2024-001 – Program Income Contact – Suzanne Tobin, Chief Financial Officer Telephone Number – (301)-832-3810 Completion Date – December 10, 2024 Corrective Action Plan: Effective immediately, the Organization will comply with the program income compliance requirement of the U.S. Department ...

Finding #2024-001 – Program Income Contact – Suzanne Tobin, Chief Financial Officer Telephone Number – (301)-832-3810 Completion Date – December 10, 2024 Corrective Action Plan: Effective immediately, the Organization will comply with the program income compliance requirement of the U.S. Department of Housing and Urban Development (HUD) Continuum of Care Program by netting program income generated from the pass-through grant to the amount to be reimbursed prior to submitting the reimbursement request to HUD, in accordance with the protocol outlined in the manual issued by the Behavioral Health Authority (BHA).

View Audit 336922 Questioned Costs: $1

Finding 518452 (2024-001)

Significant Deficiency 2024

Stepstone Academy

OH

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the Academy will perform existing c...

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the Academy will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the Academy will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the Academy has received an executed copy of the form. Upon notification of construction commencement, the Academy will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.

View Audit 336907

Finding 518451 (2024-001)

Significant Deficiency 2024

Cleveland College Preparatory School

OH

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing co...

Finding Number: 2024-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the School will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the School has received an executed copy of the form. Upon notification of construction commencement, the School will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.

View Audit 336896

Finding 518427 (2024-002)

None 2024

University of St. Thomas

TX

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

Reference Number: 2024-002 Finding: Other Instance of Noncompliance and Deficiency Status: In-progress Corrective Action: The University did not complete a Return to Title IV refund calculation within 45 days after a student had withdrawn from UST. The Assistant Director of Financial Aid ru...

Reference Number: 2024-002 Finding: Other Instance of Noncompliance and Deficiency Status: In-progress Corrective Action: The University did not complete a Return to Title IV refund calculation within 45 days after a student had withdrawn from UST. The Assistant Director of Financial Aid runs a query once a month to find students who have received Title IV or state aid and have withdrawn. The student in question did not appear on the query when we believe they should have, but was on the subsequent report. We have changed our procedures to run the query and complete Return to Title IV calculations weekly, rather than monthly. We believe this will help us find any discrepancies more quickly. We also reviewed the query and made some edits to attempt to increase accuracy. Person(s) Responsible for Implementing: Lynda McKendree, Dean of Scholarships and Financial Aid and Thuylieu Aligo, Assistant Director of Scholarships and Financial Aid Implementation Date: 09/01/2024

View Audit 336808

Finding 518425 (2024-001)

Significant Deficiency 2024

University of St. Thomas

TX

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that...

Reference Number: 2024-001 Finding: Other Instance of Noncompliance and Significant Deficiency Status: In-progress Corrective Action: Following our analysis, we have concluded that adjusting our data transmission schedule to NSC will help prevent future last minute data anomalies, ensuring that a final transmission for the term always occurs after the end date of each term. Additionally, we have identified a potential issue where NSC may fail to send graduate records to NSLDS for students who immediately re-enroll in the subsequent semester. Due to timing between the submission from NSC to NSLDS, the newer enrollment appears to be overriding the previously sent graduation record, preventing the graduation record from being sent to NSLDS. To address this, we will create a dedicated report to identify students in this situation and manually update NSLDS with the missed graduation data. Finally, there were isolated cases where a historical date adjustment was made to generate an auxiliary outcome (e.g., a grade change of Withdrawal instead of Withdrawal Failing), which made it appear as though a record change wasn't submitted in a timely manner. For these, we will discontinue this practice and employ an alternative method to derive the desired outcome (e.g., additional grade change transactions input after the withdrawal with no date adjustment). Person(s) Responsible for Implementing: Mike Acosta, Institutional Analyst, Nathan Dugat, Registrar, Lynda McKendree, Dean of Scholarships and Financial Aid Implementation Date: 11/01/2024

View Audit 336808

Finding 518403 (2024-002)

Significant Deficiency 2024

Somerset Academy of Las Vegas

NV

Allowable Costs / Cost Principles School Nutrition Programs Significant Deficiency § 200.303

Finding Number: 2024-002 – Approval of Payroll Expense Transactions Corrective Action Plan: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be ...

Finding Number: 2024-002 – Approval of Payroll Expense Transactions Corrective Action Plan: A process was put in place in January 2024 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted until proper approval is received. Personnel Responsible for Corrective Action: Nachum Golodner, Academica Director of Accounting Anticipated Completion Date: June 30, 2025

View Audit 336793

Finding 518390 (2024-003)

Material Weakness 2024

New Albany-Floyd County Consolidated School Corporation

IN

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

Finding 2024-003 – Child Nutrition Cluster - Reporting Context: During the testing of claim reimbursements, we noted two monthly reimbursements in a sample of four claims where the number of meals claimed for reimbursement did not agree to underlying meal system reports. For one claim reimbursemen...

Finding 2024-003 – Child Nutrition Cluster - Reporting Context: During the testing of claim reimbursements, we noted two monthly reimbursements in a sample of four claims where the number of meals claimed for reimbursement did not agree to underlying meal system reports. For one claim reimbursement, there was an overstatement of $9,976 and on another an understatement of $1,467. This resulted in a net over reimbursement $8,509 in the testing sample. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A new person has been hired in this position. A manager will review claim reimbursements. Anticipated Completion Date: Immediate correction.

View Audit 336751 Questioned Costs: $1

Finding 518382 (2024-001)

Material Weakness 2024

New Albany-Floyd County Consolidated School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Finding 2024-001 – Child Nutrition Cluster – Eligibility Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the ...

Finding 2024-001 – Child Nutrition Cluster – Eligibility Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis. Contact Person Responsible for Corrective Action: Leslie Beach, Director of Food Services Contact Phone Number: 812-542-2245 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: A manager will review eligibility determination and guidelines moving forward. Anticipated Completion Date: Immediate correction.

View Audit 336751

Finding 518381 (2024-005)

Significant Deficiency 2024

Solano Community College District

CA

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

Recommendation: We recommend that the District implements a process that will ensure all Title IV funds are awarded at proper amounts. Action taken in response to finding: Student’s award was adjusted to appropriately match the EFC of a subsequent ISIR that had not been processed at the time of awa...

Recommendation: We recommend that the District implements a process that will ensure all Title IV funds are awarded at proper amounts. Action taken in response to finding: Student’s award was adjusted to appropriately match the EFC of a subsequent ISIR that had not been processed at the time of awarding. Evidence of that change was provided to auditors in July 2024. Refresher training was provided to analysts to improve monitoring the output files of the ISIR import process (RCRTPxx) that identifies subsequent ISIRs received for students with locked records. Names of the contact persons responsible for corrective action: Patrick Scott and Anna Marie Troupe Planned completion date for corrective action plan: July 2024

View Audit 336749 Questioned Costs: $1

Finding 518373 (2024-003)

Significant Deficiency 2024

Solano Community College District

CA

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

Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: As this is a multi-year finding, the Financial Aid department and the Business Services department ha...

Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: As this is a multi-year finding, the Financial Aid department and the Business Services department have been working closely this term to develop a coordinated approach to avoid the issue going forward. Our procedures have been changed drastically. Once a student appears on a timeout / stale-dated check report from the vendor responsible for delivering aid to our students, we are reversing the funds and processing that reversal through COD first, then reaching out to the student to see if they need to make arrangements for correcting their address. This was done in the opposite fashion in prior years, and while it reduced delays for students who could rectify things, it carried too much risk of being forgotten and the 240 day mark being surpassed. The financial aid department has committed to placing the reversals and processing them through COD within seven business days of receiving the notification from the vendor and/or Business Services. This is far stricter than the federal regulations, but a seemingly necessary step to ensure compliance. Additionally, the Business Services team is aware of the impossibility of delivering aid beyond 240 days of the original check issuance and is helping the financial aid team to understand issuance dates in situations where Title IV aids may be commingled with other financial aid across multiple disbursement attempts. This coordination will ensure the District’s compliance going forward. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid, Shannon Beckham –Director of Business Services Planned completion date for corrective action plan: December 2024

View Audit 336749 Questioned Costs: $1

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