Corrective Action Plans

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Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU acknowledges at the time of the audit; management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract p...
Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU acknowledges at the time of the audit; management could not ascertain whether the contract with BankMobile was uploaded to the Department of Education Contract portal as there is no repository or database available to schools. This submission was completed on March 17, 2025 and documentation was retained to support the submission. Name(s) of the contact person(s) responsible for corrective action: Daniel M. Tramuta, Interim Director of Financial Aid Planned completion date for corrective action plan: March 2025
Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. Explanation of disagreement with audit f...
Recommendation: We recommend the Institute review its policies and procedures around sending entrance information to students to ensure students are receiving proper counseling and ensure entrance counseling is documented before loans disbursements are made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SOU will review its policies and procedures for Direct Loan entrance counseling to ensure all students, including GRAD PLUS loan recipients, have completed their entrance counseling or previously completed counseling is retained within the student information system. Name(s) of the contact person(s) responsible for corrective action: Daniel M. Tramuta, Interim Director of Financial Aid Planned completion date for corrective action plan: April 2025
View Audit 350358 Questioned Costs: $1
Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: Ther...
Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Student Records Specialist and University Registrar will be reviewing and revising policies and procedures related to enrollment reporting with the Clearinghouse data which then feeds into NSLDS. SOU will review calendar preparations, data collection, data submission and confirmation, error handling, file preparation documentation/instructions to identify breakdown in the process that lead to noncompliant reporting. SOU will increase monitoring of Clearinghouse data and also reach out to Clearinghouse to identify reports/tools that can assist with accurate and timely reporting. Name(s) of the contact person(s) responsible for corrective action: Rose Reinhart, Interim Registrar Planned completion date for corrective action plan: June 2025
COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit P...
COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2024-005 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action : The ACUDEN agency has not yet closed the budget year 2023-2024. Therefore, even though the contract has ended, the remaining reimbursement from the agency has not been received. Therefore, the full closing report cannot be completed until this final amount is received. As a corrective measure for finding 2024-005, the Sub Director of Finance will establish an internal control system in which the processes and compliance with the submission of accounting reports for federal programs, including Child Care, will be periodically monitored. Implementation Date: Fiscal Year 2025-2026. Responsible Person: José A. Mathews Maisonet Program Accountant
COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit P...
COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF VEGA BAJA Corrective Action Plan For the Fiscal Year Ended June 30, 2024 Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Marcos Cruz Molina, Mayor Contact Person: Mr. Edgardo Pérez, Department of Management, Administration and Budget Director Phone: (787)855-2500 Original Finding Number: 2024-003 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: In the quarterly reports (QPR), accumulated expenses are reported up to the closing date of each quarter. These expenses are assigned to the quarter in which the contractor invoices the completed work. However, in some cases, the payment is made in the quarter following the one in which the invoice was issued. This discrepancy may cause the expenses not to be accurately reflected in the quarter they were reported during the audit process. This situation will be addressed prospectively, and expenses will be assigned to the quarter in which the payment is made. Implementation Date: Fiscal Year 2025-2026. Responsible Person: José A. Torres Otero Program Accountant
Finding 2024-002 Enrollment Reporting: The Office of the Registrar acknowledges the finding related to delayed status reporting and agrees that there were instances where student information was not transmitted within the required timeframe. Although a process is now in place to support more consi...
Finding 2024-002 Enrollment Reporting: The Office of the Registrar acknowledges the finding related to delayed status reporting and agrees that there were instances where student information was not transmitted within the required timeframe. Although a process is now in place to support more consistent and timely submissions, earlier delays were influenced by staffing changes and operational challenges. To ensure ongoing compliance, the Office of the Registrar has implemented an updated submission schedule that aligns with federal reporting expectations. Enrollment and graduation data are now submitted regularly and any reporting errors are corrected and resubmitted within the 10-day recommended timeframe. These steps are part of our ongoing efforts to maintain data accuracy and comply with institutional and regulatory standards. Implementation Date: August 2025 Person Responsible: Brianna Mendez, Student Data Specialist, Office of the Registrar
II. Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material weakness): We observed the following conditions in connection with our testing of the TRIO programs: (a) UB Eligibility Test: Of the 17 students selected for testing, one (1) student’s citizenship could not b...
II. Finding 2024-002 - U.S. Department of Education (USDE), TRIO Cluster Programs (material weakness): We observed the following conditions in connection with our testing of the TRIO programs: (a) UB Eligibility Test: Of the 17 students selected for testing, one (1) student’s citizenship could not be determined, two (2) students did not provide any income information on the application, ten (10) students did not provide tax returns to verify low income as reported. (b) ETS Eligibility Test: Of the 17 students selected for testing, seven (7) students' citizenship status could not be determined, documentation to support enrollment status was not provided for 17 students, one (1) student did not have any information uploaded, and one (1) student has a birthdate discrepancy. (c) Educational Opportunity Center (EOC) Eligibility Test: Of the 17 participants selected for EOC testing, 17 did not have an enrollment agreement, acceptance letter, nor tax documents uploaded to adequately test the attributes, and one (1) student did not have a signature page for the EOC application. Auditor's Recommendation – We recommend the College ensure that all required documentation is submitted prior to determining the participants' eligibility. Corrective Action – Tougaloo College Administration understands the importance of federal compliance. The Vice President for Strategic Initiatives & Social Justice has direct management oversight of the TRIO programs. The lack of internal controls related to UB Eligibility Test, ETS Eligibility Test, and EOC Eligibility Test (verification of citizenship, income information, tax refunds, documentation of enrollment status, enrollment agreement, and birthdate verification), a non-recurring finding, were largely caused by a high degree of staff turnover and lack of experience in the front-line staff directly responsible for these controls. Although it has proven difficult to hire and retain highly qualified staff due to higher salaries paid by other institutions for similar positions in our market, the Executive Director of the TRIO programs and leadership team has implemented the following actions to correct the findings: 1. Continue to recruit and develop internal protocols to more fully retain highly qualified personnel. 2. Continue to train staff and increase staff training specific to reviewing the proper documentation required for attending the programs. 3. Include an additional level of early review by the Executive Director and other senior program staff to verify compliance at multiple stages of program involvement by students, including when students are initially recruited and enrolled. 4. Internal federal compliance testing will be a required criteria for the staff annual evaluations reviewed by the Executive Director of TRIO programs and the Vice President for Strategic Initiatives & Social Justice.
I. Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (material weakness): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1) 11 out of 60 st...
I. Finding 2024-001 - U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (material weakness): We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs: 1) 11 out of 60 students did not meet Satisfactory Academic Progress (SAP) for the academic year. The College did not provide supporting documentation for successful appeals and allowed the students to receive Title IV funding. 34 CFR 668.34. Questioned costs for this finding is $180,794. 2) Nine (9) of the 10 students tested for Federal Work-Study Payroll had missing and/or incomplete timesheets. 34 CFR Part 675. 3) Six (6) of the 10 students tested for withdrawals and the return of Title IV funds did not have their Title IV program funds returned within the 45-day requirement. HEA, Section 484B & 34 CFR 668.22. 4) Entrance and exit counseling documentation was not provided for first time borrowers, withdrawn students or graduated students. 34 CFR 685.304. 5) Cost of Attendance Budgets to determine students unmet need were not provided by the College. 34 CFR 685.102(b). 6) The Office of Financial Aid submitted unreconciled expenditures within the Fiscal Operations Report and Application to Participate (FISAP) for Federal Pell Grant, Federal SEOG and Federal Work-Study. 7) The College did not reconcile all Title IV programs between the Office of Financial Aid and the Business Office including Federal Pell Grant, Federal SEOG, Federal Work-Study and Federal Direct Loans. CFR 685.300(b)(5). Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Auditor's Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and do not recur in future periods. Moreover, internal controls over compliance with federal program regulations should be revisited to ensure adequate supervisory controls, quality assurance reviews of processes, and policies and procedures are being updated and adhered to for compliance purposes. Corrective Action – Tougaloo College Administration understands the importance of federal compliance. The collective knowledge of others within the Division of Finance and Administration reinforces the expertise of the four financial aid staff members. The Vice President of Finance and Administration, in collaboration with the Vice President for Enrollment and Student Services, who has direct oversight of the financial aid department, has implemented professional development targeted training on the continuous changes in Title IV program management. In addition to addressing/paying the questioned costs found with improper documentation of Satisfactory Academic Progress with USDE, the following allows for corrective actions while continuing to engage with the Title IV student financial aid programs: 1. Financial Aid team members become certified in the enterprise resource program module, specific to financial aid. 2. Annually, one or more staff members attend the national conference for student aid administrators, which focuses on deepening understanding of federal regulations, exploring new legislation enacted by Congress, gaining practical experience with student loan data systems, and networking with industry peers who offer support identifying and effectively addressing challenges associated with financial aid operations. 3. Attend monthly and quarterly training via knowledge base webinars on: Satisfactory Academic Progress (SAP), Work-study process for students and staff, student loan process, the return of Title IV funds, and reconciling expenditures with the Business Office. 4. Utilize additional resources from the U.S. Department of Education’s Minority-Serving and Under-Resourced Schools Division for administering Title VI Aid.
View Audit 350319 Questioned Costs: $1
1. Implement new communication channels to align process to NSLDS and the USDoE.  Engage with NSLDS: Requested an access token for the data manager to monitor and reconcile data submitted.  Reach out to NSLDS to coordinate new reconciliation reports out of NSLDS database. 2. Training  Maintain su...
1. Implement new communication channels to align process to NSLDS and the USDoE.  Engage with NSLDS: Requested an access token for the data manager to monitor and reconcile data submitted.  Reach out to NSLDS to coordinate new reconciliation reports out of NSLDS database. 2. Training  Maintain sustained training and preparation for the staff. 3. Implement a weekly review process to double­check the entries for changes in enrollment reporting in NSLDS.  Implement a Document Changes and Actions Log: Keep detailed records of all changes made to procedures and actions taken to address the audit findings. This documentation can be useful for future reviews.  The Registrar will assure that all changes (LOA, withdrawals, re­ entries, and reclassifications, completions, graduations) are entered weekly and documented across all databases (NSLDS, Jenzabar student record, SRS, others as applicable).
Recommendation We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete. We recommend the Department implement effecti...
Recommendation We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete. We recommend the Department implement effective processes and procedures to maintain the submitted reports and the documentation used to prepare the reports in the files of the Department. Management Response Corrective Action: The Department understands the issues and is continuing to take corrective action to improve reporting. In the past the Department has shifted its priority to onboarding across the Department, and we have onboarded a Grants Unit Manager to oversee the reporting requirements of all federal grants. The Grants Unit will focus on procedures to ensure the reporting requirements are met. A procedural checklist will be implemented to ensure that: 1. the recipient share section is completed, 2. that financial reports are submitted to the Department timely, and 3. all Performance Progress Reports as submitted. Due Date of Completion: June 30, 2025 Responsible Person(s): Deputy Cabinet Secretary, Grants Unit Manager
Personnel Responsible for Corrective Action: Julie McGovern, Chief Financial Officer Anticipated Completion Date: September 30, 2025 Corrective Action Plan: Due to turnover in the Business Office, the corrective plan identified with the FY23 audit was not completed. The corrective action remains th...
Personnel Responsible for Corrective Action: Julie McGovern, Chief Financial Officer Anticipated Completion Date: September 30, 2025 Corrective Action Plan: Due to turnover in the Business Office, the corrective plan identified with the FY23 audit was not completed. The corrective action remains the same. The Business Office will implement a systematic process to properly track fixed assets that will include a description of the property, a serial / identification number, the source of the funding for the property including the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any disposition information should the asset be sold, retired or disposed. A key resource has been obtained that will enable this project to be completed in the timeframe noted.
Finding No: 2024-008 ALN No.: 17.258 Program Title: WIOA Adult Program 17.259 Program Title: WIOA Youth Activities 17.278 Program Title: WIOA Dislocated Worker Formula Grant (WIOA Cluster) Grant Award No.: AA347643L0 2022 AA347645P0 2022 Condition During the audit, it was noted that an excess 0.63% ...
Finding No: 2024-008 ALN No.: 17.258 Program Title: WIOA Adult Program 17.259 Program Title: WIOA Youth Activities 17.278 Program Title: WIOA Dislocated Worker Formula Grant (WIOA Cluster) Grant Award No.: AA347643L0 2022 AA347645P0 2022 Condition During the audit, it was noted that an excess 0.63% of funds were allocated for employment and training activities for adults and dislocated workers. The lead WIOA accountant who completed the close-out report at issue is no longer employed by DLIR. Corrective Action Plan Following the departure of the lead WIOA accountant who completed the subject closeout report, the Administrative Services Office (ASO) has heightened fiscal training and internal controls among its two new WIOA accountants to ensure that the federal award is managed in compliance with all terms and conditions of the award, including requirements pertaining to subrecipient earmarking, so no more than 15% of funds are expended towards the administrative costs category for the WIOA Title I Adult, Dislocated Worker, and Youth Programs. The Workforce Development Council (WDC) is also in the process of contracting with a selected vendor to develop in-depth, in-person fiscal training to be held in June 2025 that will support fiscal staff, including local areas’ fiscal staff, to better understand and navigate the financial management and budgeting for Workforce Innovation and Opportunity Act (WIOA) services. Person Responsible Lynn Araki-Regan Anticipated Date of Completion June 30, 2025
Finding 540428 (2024-002)
Significant Deficiency 2024
Reference Number: 2024-002 Name of Contact Person: Armine Trashian, Controller Corrective Action: The City will implement recommendations and maintain all compliance-related documentation to ensure all necessary documents are maintained in accordance with ongoing compliance requirements. Proposed...
Reference Number: 2024-002 Name of Contact Person: Armine Trashian, Controller Corrective Action: The City will implement recommendations and maintain all compliance-related documentation to ensure all necessary documents are maintained in accordance with ongoing compliance requirements. Proposed Completion Date: June 30, 2025
Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies a...
Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies and procedures, as necessary, to address all current regulatory requirements. The Department’s multifamily monitoring for all projects in the HOME period of affordability will be completed prior to June 30, 2025. As part of the monitoring process, the Department will document all records requiring annual or semi-annual oversight and review for compliance with HOME requirements. Should the monitoring result in any findings requiring corrective action, the Department will ensure all findings are addressed by September 30, 2025. Anticipated Completion Date May 2025 Contact Information of Responsible Official Name: Augustine Ramirez Title: Division Manager, DPWP Community Development Division Phone: 559-600-4266
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Child Welfare Services (“CWS”) recognizes that licensing case files from neighbor islands (Maui, West Hawaii, and Kauai) came late or not at all, and this lack of ability to review the recor...
Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Child Welfare Services (“CWS”) recognizes that licensing case files from neighbor islands (Maui, West Hawaii, and Kauai) came late or not at all, and this lack of ability to review the records significantly contributed to the errors. Moving forward, CWS will ensure easier records identification by geographical location and begin the neighbor island’s audits first, allowing extra time for records travel to review site. CWS also notes that additional communication and information sharing with auditors would have been helpful to ensure understanding of expectations prior to on site audit. The communications requested would resemble a pre audit information sharing call, an on site audit entry meeting with key agency staff, and an audit exit conference to discuss findings before the final report is generated. Corrective Action Taken or Planned: 1. CWS staff will be informed of the audit findings and corrective action plan, emphasizing the importance of: A. Providing requested records in advance of the audit, B. Diligent compliance with policies and procedures, C. Supervisor coaching, support and review of records/documents for completeness, D. The impact of individual unit records maintenance performance on the outcome of the audit and this corrective action plan. 2. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. Staff will: A. Continue to ensure staff are securing the Adoption Assistance and Legal Guardian permanency assistance forms that provide notice for age changes and payment increases. B. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated, and ensuring it is filed in eligibility record. C. Locate or reprint and file missing “Certificate of Approvals.” D. Locate missing clearances in records not provided for review or re run them if not located in records reviewed. Please note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. E. Administrators to work with courts to ensure court orders contain the required language and are secured in a timely fashion. i. Secure missing termination of parental rights order. ii. Secure court order supporting “reasonable efforts.” iii. Secure missing police protective custody documentation or voluntary foster custody agreement for three cases. F. For young person(s) in Imua Kakou (“IK”) who turned 18 while in care. i. CWS will secure a letter for the record, from the school that the young person is attending, which notes when the young person is expected to graduate. ii. Work with IK providers and IK liaison to make sure logs and meeting minutes are in SHAKA. iii. Document (reason for) continuation of monthly subsidy payments after youth turned 18. 3. CWS has identified the Eligibility Unit (“FPPEU”) record as the primary record for audits with the Licensing record and other case files as secondary. 4. Unit staffs (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. A. The FPPEU Administrator and supervisors will review the eligibility unit record checklist and ensure use of checklist will lead to a complete record containing all required documentation. B. FPPEU staff will review error records identified in this audit, following checklist and secure missing documentation, update inaccurate information and verify that all necessary documentation is present. i. Staff will be given coaching/supervisory support to correctly complete documentation. ii. Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. iii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. C. The Licensing Unit Section Administrator and supervisors will review error records identified in this audit, secure missing documentation, update inaccurate information, and verify that all necessary documentation is present. i. Staff will be given coaching/supervisory support to correctly complete documentation. ii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. 5. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. A. MICU staff will audit records to verify that corrective actions have been completed for case specific audit findings. This includes verifying that records contain a note explaining updated information or information gathered due to audit. B. MICU will work with Branch Administrators, Section Administrators, Social Services Assistants (“SSA”) and program personnel to ensure file updates with completion of missing information. C. MICU will verify accuracy of DOC calculations for case specific errors noted in this audit, while supervisors will verify accuracy of DOC calculations on an ongoing basis. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. 7. In preparation for future audits, CWS will update the file identification and secure transport process as follows: A. MICU will send a separate email for records request to each neighbor island, identifying only their records, rather than sending a joint, multi-island, records request. B. The records request email sent by MICU will include a submittal deadline that will accommodate extra time for secured travel of records between islands to ensure all records arrive on time. C. MICU and Branch will review records submitted, ensuring that all records are available to the auditors for review. Completion Date: On going Responding Official(s): Kisha C. Raby, Social Services Division Program Development Administrator; Tonia Mahi, Social Services Division Assistant Child Welfare Services Branch Administrator
View Audit 350226 Questioned Costs: $1
2024-003 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the audit recommendations and remains committed to strengthening grant management and financial oversight. This year’s challenges in grant reconciliation stemmed from overlapping prior-year FTA claims is...
2024-003 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the audit recommendations and remains committed to strengthening grant management and financial oversight. This year’s challenges in grant reconciliation stemmed from overlapping prior-year FTA claims issues, pending grant amendments, and limited time, as noted in Finding 2024-002. Additionally, the increased complexity of federal grants following the pandemic required adjustments to allocation methods and financial reporting. To address these issues, staff has refined internal processes, including improving worksheets, enhancing review procedures, and consolidating grant data into a single summary sheet for better tracking. The 2024 FTA Triennial Review acknowledged these improvements, and the corrective action plan was considered sufficient, with recommendations to closely monitor grant activity and update the worksheets as necessary. Moving forward, staff will continue formalizing procedures for expense allocation, improve reconciliation processes, and ensure grant expenditures align with available funding. Grant tracking will provide a clearer overview of balances, deadlines, and remaining funds. The Finance department also adjusted its billing practices to reconcile expenses earlier in the reporting cycle, allowing sufficient time for review and claim adjustments. Regarding the overclaimed amounts of $183,548 and $175,143, staff will work with the FTA to determine whether repayment is required or if the funds can be applied to future eligible expenses. These efforts will strengthen compliance, improve accuracy in financial reporting, and overall grant management. Responsible Party: Director of Finance & Administration Implementation Date: Ongoing; full implementation expected by December 31, 2025
Finding Number: 2024 – 003 – Reporting Grantor: Department of Labor (DOL)-Office of Disability Employment Policy (ODEP) Program Name: Disability Employment Policy Development Award Name: Disability Employment Policy Development Award Number: 23475OD000001-01-00 (passthrough ID 24-SA-053-3203) Assist...
Finding Number: 2024 – 003 – Reporting Grantor: Department of Labor (DOL)-Office of Disability Employment Policy (ODEP) Program Name: Disability Employment Policy Development Award Name: Disability Employment Policy Development Award Number: 23475OD000001-01-00 (passthrough ID 24-SA-053-3203) Assistance Listing Titles: Disability Employment Policy Development Assistance Listing Numbers: 17.720 Award Year: Fiscal Year 2024 Passthrough Entity: The Council of State Governments Corrective Action Plan: Cornell acknowledges that performance reports for this award were not filed timely. To address this omission the university will reinforce the importance of timely reporting during routine training and update sessions in the coming year and remind departments that these requirements are stated in the award documents and the research administration system. Responsible individual: Mary-Margaret Klempa, Senior Director, Office of Sponsored Programs
Finding Number: 2024 – 002 – Notification prior to disbursement of Title IV funds Grantor: Department of Education Program Name: Student Financial Assistance Cluster Award Name: Federal Pell Grant Program Award Numbers: not applicable Assistance Listing Titles: Federal Pell Grant Program Assistance ...
Finding Number: 2024 – 002 – Notification prior to disbursement of Title IV funds Grantor: Department of Education Program Name: Student Financial Assistance Cluster Award Name: Federal Pell Grant Program Award Numbers: not applicable Assistance Listing Titles: Federal Pell Grant Program Assistance Listing Numbers: 84.063 Award Year: Fiscal Year 2024 Passthrough Entity: various Corrective Action Plan: Cornell acknowledges that Title IV financial aid was disbursed before a student received their official aid offer due to a manual processing error. To prevent this issue in the future, Cornell implemented a new Peoplesoft system control called a “user edit message” in August 2024. • The new user edit message prevents Title IV and other financial aid disbursements until the system has generated and sent an official aid offer in August 2024. • The new user edit message is assigned (and cleared, when appropriate) via batch system processes that run prior to daily disbursement processes. • On-demand queries were also developed to monitor performance of the control as well as to proactively identify and address any currently unknown circumstances that may result in similar outcomes. • The new controls were implemented in all currently active aid years and will remain as standard controls in future years. Responsible individual: Kevin J. Jensen, Executive Director, Office of Financial Aid and Student Employment
Finding Reference: 2024-012 - SFA Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has established a formalized procedure, effective immediately, to ensure the accurac...
Finding Reference: 2024-012 - SFA Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: Jackson State University has established a formalized procedure, effective immediately, to ensure the accuracy and compliance of the annual Fiscal Operations Report and Application to Participate (FISAP). As part of this process, a FISAP Review Committee will be created to oversee the review of the FISAP and all supporting documentation at least three weeks before the official submission deadline. The FISAP will be prepared by the Executive Director of Student Financial Aid Services and Scholarships, who will also gather and compile all necessary supporting documentation. This completed report, along with all relevant data, will then be submitted to the FISAP Review Committee for thorough examination. The committee will verify the accuracy of all figures and ensure that the supporting documents meet FISAP compliance requirements. Submission of the FISAP will only proceed once the FISAP Review Committee has reached a consensus confirming the accuracy and completeness of the report. This structured review process will help safeguard against errors, enhance compliance, and ensure that JSU meets all federal reporting standards. Estimated Completion Date: September 1, 2025
Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of ...
Finding Reference: 2024-011 - Program Income, Ryan White (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Based on feedback received from a Sponsor-led site visit in 2024, UMMC practices and policies are appropriately aligned with the intent of the program. UMMC will make efforts to ensure that all practices and policies are clearly documented and evaluated periodically. Estimated Completion Date: June 30, 2025
Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (ASU) Responsible Official: Kisha Bond, Registrar Corrective Action Planned: ASU must report enrollment status for students in the NSLDS database within a 60-day window. ASU reported the enrollment status for the ...
Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (ASU) Responsible Official: Kisha Bond, Registrar Corrective Action Planned: ASU must report enrollment status for students in the NSLDS database within a 60-day window. ASU reported the enrollment status for the students but not within 60 days. Moving forward, ASU will monitor the activity for the NSLDS database and submit student enrollment data on a timely basis. Estimated Completion Date: August 29, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (JSU) Responsible Official: Ms. Lakesha Tubbs, Registrar Corrective Action Planned: Jackson State University will implement a multi-tiered enrollment reporting schedule to enhance accuracy and prevent certification and enrollment reporting errors. Effective immediately, JSU will submit an initial enrollment reporting file to the National Student Clearinghouse at the beginning of each term. Additionally, two subsequent enrollment reports will be submitted—one at midterm and another within ten (10) days of final grade publication at the end of the term. To ensure consistency, transparency, and alignment across university departments, JSU will establish an Enrollment Reporting Oversight Committee composed of representatives from key university offices. This committee will convene quarterly throughout the academic year to review enrollment reporting processes, address potential discrepancies, and implement best practices. By fostering collaboration amongst stakeholders, JSU will ensure compliance, accuracy, and efficiency in enrollment reporting. Estimated Completion Date: May 9, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (MSU) Responsible Official: Emily Shaw, University Registrar Corrective Action Planned: In addition to reporting in a timely manner to National Student Clearinghouse, MSU will also begin to monitor NSC’s reports to NSLDS. Estimated Completion Date: June 15, 2025 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (MVSU) Responsible Official: Jeffrey Loggins, Director of Student Records Corrective Action Planned: The Office of Student Records will review the schedule submission dates for enrollment reporting to the National Student Clearinghouse to ensure compliance with certifying student enrollment within 60-day timeframe from program enrollment effective date. Additionally, enrollment reporting data will be carefully reviewed in an effort to avoid future enrollment errors. Moreover, this may include adding an additional date to report enrollment data during semesters. Estimated Completion Date: February 15, 2026 Finding Reference: 2024-005 - SFA Special Tests and Provisions - Enrollment Reporting (UMMC) Responsible Official: Emily Cole, Executive Director Office of Enrollment Management Corrective Action Planned: As an internal control measure, the Office of Enrollment Management has identified two individuals to verify all enrollment changes are appropriately captured in the National Student Loan Data System (NSLDS) within the 60-day time period. The Senior Record Specialist and Senior Enrollment Data Specialist will review pertinent records in the NSLDS monthly to verify all information has been correctly conveyed from the National Student Clearinghouse System. Estimated Completion Date: Effective immediately
Finding Reference: 2024-003 - SFA COD Reporting (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU reconciles Pell and federal direct student loans to COD monthly. The reconciliation is done timely, and ASU will continue to reconcile and pr...
Finding Reference: 2024-003 - SFA COD Reporting (ASU) Responsible Official: Debra Reynolds, Assistant Director of Financial Aid Corrective Action Planned: ASU reconciles Pell and federal direct student loans to COD monthly. The reconciliation is done timely, and ASU will continue to reconcile and provide evidence of review. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships; Ms. Lakesha Tubbs, Registrar; Adrienne Walls, Bursar Corrective Action Planned: In previous years, Jackson State University has extended the purge and registration dates to better serve a high number of students from underrepresented communities and low-income backgrounds, ensuring that they have the opportunity to complete the enrollment process. However, this practice has led to inaccurate reporting of enrollment dates. Moving forward, Jackson State University will work with new, continuing, and readmit students beginning in April 2025 through the start of the Fall 2025 semester on August 18, 2025, to ensure all enrollment materials are completed before the beginning of each term. As part of this effort, Jackson State University has redesigned its new student orientation process with the goal of ensuring students are completely registered before arriving on campus for the fall semester. Within this new model, a dedicated position has been created for First-Time Freshmen to establish proactive outreach and education regarding costs to students and families. The redesigned orientation process places a strong emphasis on First-Time Freshmen, guaranteeing they receive the necessary guidance and support to successfully transition into college life. Additionally, the university will enforce enrollment deadline dates to prevent inaccurate enrollment data and eliminate errors in disbursement records. In addition to enhancing the student enrollment process, JSU is also taking steps to strengthen financial accountability. Furthermore, Jackson State University’s Financial Aid Office, in coordination with its Business Office, will begin holding regularly scheduled reconciliation meetings at the end of each month. These meetings will ensure that the amounts disbursed on both sides align and that figures from both departments match what has been drawn down and either paid out or returned to the U.S. Department of Education Common Origination and Disbursement (COD). Both departments will also utilize an institutional reconciliation document to add another layer of control and prevent errors. These strategic improvements reflect Jackson State University’s ongoing commitment to compliance, operational efficiency, and student success. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The internal control procedures will initiate a reconciliation of disbursement dates against COD data. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-003 - SFA COD Reporting (UMMC) Responsible Official: Davita Weary, Director of Student Financial Aid Corrective Action Planned: Reconciliations will be reviewed with Kelly Dismuke, Director of Finance Operations, on a monthly basis. Estimated Completion Date: March 26, 2025 Finding Reference: 2024-003 - SFA COD Reporting (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: USM reconciles Pell and DL monthly. Copies of reconciliations are saved in a shared drive and can be made available upon request. The reconciliations will be reviewed on a monthly basis by the Financial Aid Assistant Director (Alanna McDonald) and Director (David Williamson), and the Bursar (Barbara Madison) when necessary. Estimated Completion Date: March 17, 2025
Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: The Jackson State University Division of Financial Aid has implemented a co...
Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director of Student Financial Aid Services and Scholarships Corrective Action Planned: The Jackson State University Division of Financial Aid has implemented a comprehensive training initiative to strengthen compliance, improve accuracy, and enhance staff proficiency in federal student aid verification. As of May 7, 2024, ongoing training has commenced for all financial aid staff on the 2024-2025 verification process and required documentation. Additionally, beginning April 4, 2025, the department will launch continuous training on verification procedures and Federal Student Aid compliance to ensure staff remains informed of regulatory updates and best practices. To further enhance accuracy and accountability, the department will collaborate with the Department of Information Technology (IT) to develop internal error reports that proactively identify discrepancies in student records. An internal checklist will also be implemented to ensure that each student selected for verification by the U.S. Department of Education has submitted all required documentation. This checklist must be reviewed and signed off by the Executive Director of Student Financial Aid Services and Scholarships before final processing. As part of the department’s transition to a more automated verification process, JSU will integrate Campus-Logic, powered by Ellucian, to streamline operations and reduce manual errors. Comprehensive training sessions will be conducted to ensure financial aid staff are proficient in using the platform. Additionally, an internal checklist within Campus-Logic will be established to facilitate structured review and compliance tracking. A final verification review will be conducted by the Executive Director of Student Financial Aid Services and Scholarships to uphold accuracy and federal compliance, ultimately mitigating errors and improving audit outcomes. Estimated Completion Date: December 19, 2025 Finding Reference: 2024-008 - SFA Special Tests and Provisions - Verification (MVSU) Responsible Official: Angela Fant, Director of Financial Aid Corrective Action Planned: The verification process will ensure all student data is accurate and corrected by staff. Estimated Completion Date: September 30, 2025
Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver ...
Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver credit balance to students. The contract with the servicer should have been uploaded to the Dept of Ed database. Since the audit finding, the contract has been uploaded. ASU will upload the contract timely going forward. Estimated Completion Date: Effective Immediately Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (MVSU) Responsible Official: Mrs. Brittney Manuel-Carpenter, Account Receivable Supervisor Corrective Action Planned: MVSU acknowledged the findings of reference 2024-06 SFA-Special Test- Using a Servicer to Deliver Title IV Credit Balances. MVSU acknowledges that the servicer contract is uploaded to the Department of Education database and is available for viewing. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: University will contact the Department of Education Cash Management to correct the URL link. While the link was broken on the Cash Management site it was active on the USM Business Services website: https://www.usm.edu/business-services/refunds.php and is continually maintained on their site. Estimated Completion Date: April 1, 2025
Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that...
Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that addresses all 7 required elements of the GLBA regulations: • Review GLBA Requirements: Conduct a thorough review of the Gramm-Leach-Bliley Act (GLBA) regulations to understand the 7 required elements. - Completed • Gap Analysis: A gap analysis has been performed to identify missing elements in the current information security program. - Completed • Program Development: Develop and implement policies and procedures to address the identified gaps. This includes administrative, technical, and physical safeguards. - In Progress • Training: Provide training to staff on the new policies and procedures to ensure compliance and proper implementation. - Planning • vCISO Support: Leverage the expertise of the newly hired virtual Chief Information Security Officer (vCISO) to guide the development and implementation of the information security program. - In Progress 2. Conduct a Comprehensive Risk Assessment to identify and address significant gaps in the risk assessment process: • Risk Assessment Framework: Establish a risk assessment framework that aligns with GLBA requirements. - In Progress • Identify Risks: Identify potential risks to the confidentiality, integrity, and availability of customer information. – In Progress • Evaluate Controls: Assess the effectiveness of existing controls and identify areas for improvement. – In Progress • Mitigation Plan: Develop a risk mitigation plan to address identified vulnerabilities and implement appropriate controls. - Planning • vCISO Support: Utilize the vCISO's expertise to ensure a thorough and effective risk assessment process. – In Progress 3. Monitoring and Continuous Improvement to ensure ongoing compliance and continuous improvement of the information security program: • Regular Audits: Conduct regular audits to ensure compliance with GLBA regulations and the effectiveness of the information security program. – Planning • Feedback Mechanism: Establish a feedback mechanism to gather input from staff and stakeholders on the effectiveness of the program. - Planning • Update Policies: Periodically review and update policies and procedures to address emerging threats and changes in regulations. – In Progress • vCISO Support: Engage the vCISO in monitoring and continuous improvement efforts to maintain high standards of information security. – In Progress 4. Reporting and Accountability to ensure accountability and transparency in the implementation of the corrective action plan: • Assign Responsibility: Assign responsibility for the implementation of the corrective action plan to a dedicated team or individual. - Planning • Progress Reports: Provide regular progress reports to senior management and stakeholders on the implementation of the corrective action plan. - Planning • Documentation: Maintain thorough documentation of all actions taken to address the identified issues. - Planning • vCISO Support: Include the vCISO in reporting and accountability processes to ensure expert oversight and guidance. – In Progress By following this corrective action plan and leveraging the expertise of the vCISO, MVSU can address the deficiencies in its information security program and risk assessment process, ensuring compliance with GLBA regulations and protecting customer information effectively. Estimated Completion Date: November 30, 2025
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