Corrective Action Plans

Finding 524571 (2024-102)

Significant Deficiency 2024

ME

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

The Agency will implement appropriate processes and controls to ensure the Schedule of Federal Awards contains complete and accurate data.

View Audit 344021

Finding 524567 (2024-002)

None 2024

Oregon College of Oriental Medicine

OR

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding: 2024-002 Reporting Department’s Response: We concur Corrective Action: Since the closure of the College will result in no further student loan activity, no immediate corrective action is considered necessary. Contact: Phil Lundberg Anticipated Completion Date: Immediately

View Audit 344009

Finding 524564 (2024-001)

Significant Deficiency 2024

The Chicago School-Cal INC Dba the Chicago Sch of Pro Psychology

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federa...

Corrective Action Plan – The Chicago School Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $528,450 to $1,238,306, from November 13, 2023, to December 18, 2023. While the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the amounts were not returned within the seven-day period as required. Summary: The College draws a portion of funds for student stipends while award reconciliation is in progress to ensure timely disbursement. An administrative oversight led to excess cash being held longer than allowed. Specifically, the prior stipend drawdown was not netted out when calculating subsequent fund requests, resulting in excess cash being held for 24 business days. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure compliance with the seven-day return requirement. 2. Process Change: Going forward, the College will refrain from drawing funds for student stipends until reconciliations have been fully completed. This will ensure that funds are drawn in alignment with actual disbursement needs, reducing the risk of excess cash. 3. Internal Control Strengthening: The College will enhance internal controls around cash management to ensure that excess cash instances are identified and corrected promptly. 4. Staff Training: All relevant staff will undergo training on revised cash management procedures and the importance of timely reconciliation and returns. 5. Improved Monitoring: The College will implement a more robust monitoring process to track excess cash and ensure compliance with Federal regulations, including daily checks during peak disbursement periods. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343996

Finding 524562 (2024-001)

Significant Deficiency 2024

Pacific Oaks Education Corporation

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title...

Corrective Action Plan – Pacific Oaks Education Corporation Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Guidance of the Department of Education (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had excess cash for the Federal Direct Student Loan program, ranging from $1,335,590 to $4,774,182, from September 6, 2023, to September 13, 2023. The excess cash exceeded the one-percent tolerance of prior year drawdowns, and the funds were not posted to students' ledgers within the three-business-day period as required. Summary: The College draws a portion of funds early to ensure the timely disbursement of stipends to students, while the reconciliation process is still underway. However, the funds were not posted to students’ ledgers within the required three days, leading to a violation of the federal cash management requirements. The issue was related to administrative oversight in the processing of the drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure funds are posted to students’ ledgers within the three-business-day requirement. 2. Process Change: The College will refrain from drawing funds early to cover stipends until all necessary reconciliations are completed, ensuring compliance with the required disbursement timeline. 3. Internal Control Strengthening: The College will strengthen internal controls by implementing more rigorous checks to ensure timely posting of funds to students' accounts after drawdowns. 4. Staff Training: Relevant staff members will undergo training on the updated procedures and the importance of timely posting of funds to student ledgers. 5. Improved Monitoring: The College will institute enhanced monitoring and tracking of funds after drawdowns to ensure that the required posting timeframe is consistently met. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343993

Finding 524554 (2024-001)

Significant Deficiency 2024

University of Miami

FL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

UM management acknowledges that the status changes for 5 out of 40 students selected were not reported to NSLDS within the required 60-day timeframe. This delay was caused by unexpected technical issues during the submission process to the National Student Clearinghouse. Corrective Action Plan UM ...

UM management acknowledges that the status changes for 5 out of 40 students selected were not reported to NSLDS within the required 60-day timeframe. This delay was caused by unexpected technical issues during the submission process to the National Student Clearinghouse. Corrective Action Plan UM management has since implemented a new process for reporting submission to bypass the technical issues. Timeline for Action Plan The new process was implemented in March 2024. Responsible JndjviduaJs Allen Augustin, Associate Registrar

View Audit 343977

Finding 524548 (2024-005)

Significant Deficiency 2024

Gibraltar Area School District

WI

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Significant Deficiency § 200.214

Suspension and Debarment Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) Procedures will be updated to include documentation of verification that a vendor has not been suspended or debarred. A record of this verification will be retained. Responsible official: Mark ...

Suspension and Debarment Federal Assistance Listing Number: Special Education Cluster (84.027 and 84.173) Procedures will be updated to include documentation of verification that a vendor has not been suspended or debarred. A record of this verification will be retained. Responsible official: Mark Lindem, Business Manager, mark.lindem@gibraltar.k12.wi.us Anticipated Completion Date: June 30, 2025

View Audit 343957

Finding 524542 (2024-003)

Significant Deficiency 2024

Donnelly College

KS

Student Financial Aid Matching / Level of Effort / Earmarking

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: The College has procedures in place that are supposed to prevent the awarding of students in verification. The Student Information System (Empower) has a feature for tracking students in verificati...

Contact Person: Ron Dempsey, Controller Views of Responsible Officials and Planned Corrective Action: The College has procedures in place that are supposed to prevent the awarding of students in verification. The Student Information System (Empower) has a feature for tracking students in verification. That tracking system did not prevent the awarding of Title IV aid. Therefore, the college will implement a backup tracking system to help track students in verification. Anticipated Completion Date: March 31, 2025

View Audit 343943

Finding 524514 (2024-002)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College review their records to locate the missing promissory notes. If the signed promissory notes can’t be located, the College should assess if there is sufficient documentation to support the loan such as repayment history, documentation showing the original payment was accepted by the student, etc. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the audit testing, all Perkins loan MPNs were located and the College is finalizing its assignment of the loans to the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO and Grant Drinnen, Cash and Accounts Receivable Specialist Planned completion date for corrective action plan: January 31, 2025

View Audit 343891

Finding 524499 (2024-002)

Significant Deficiency 2024

Franklin Community School Corporation

IN

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency § 200.303

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant...

FINDING 2024-002 Finding Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed; Allowable Costs/Cost Principles Summary of Finding: An effective internal control system was not designed at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. The School Corporation had designed a system of internal controls to ensure payroll expenditures charged to the grant fund were allowable. However, 2 of the 44 expenditures tested did not show have documentation that the control had been applied and operated effectively. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements and apply the controls consistently to all transactions. Contact Person Responsible for Corrective Action: Kerri Powers-Hoffman, Payroll Specialist Contact Phone Number and Email Address: hoffmank@franklinschools.org, 317-346-8738 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Payroll Specialist will ensure the files posted to the shared drive for the monthly board meetings contain all payroll claims necessary for approval each month. The Payroll Specialist also will review the prior months file to ensure no payroll claims were skipped, which is what resulted in this finding. Anticipated Completion Date: This corrective action has already been implemented.

View Audit 343871

Finding 524497 (2024-001)

Material Weakness 2024

Franklin Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.303

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection repor...

FINDING 2024-001 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not designed, nor implemented a system of internal controls, to ensure the annual Elementary and Secondary School Emergency Relief (ESSER) annual Data Collection reports (Reports) were complete and accurately submitted. The School Corporation Reports were reviewed by the Assistant Deputy Treasurer and submitted by the Chief Financial Officer; however, there was no documentation provided to verify that the oversight or review process to prevent, or detect and correct, errors were performed during the audit period. The State Board of Accounts recommends that the School Corporation’s management establish a system of internal controls related to the federal award and the Reporting compliance requirement which includes documentation of the operation of the controls. Contact Person Responsible for Corrective Action: Camilla Hoffman, Assistant Deputy Treasurer Contact Phone Number and Email Address: hoffmanca@franklinschools.org, 317-346-8748 Views of Responsible Officials: We concur with the finding, but we would like to emphasize that the review had been implemented. It just was not documented by the reviewer. Description of Corrective Action Plan: The Assistant Deputy Treasurer will begin documenting her review of the required ESSER reporting via email, so that this review can be verified by auditors or other inquirers. Anticipated Completion Date: This corrective action will be added to the district’s procedures immediately, but ESSER reporting is not anticipated until later in the Spring 2025.

View Audit 343871

Finding 524492 (2024-005)

Material Weakness 2024

Henning Public School District 545

MN

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

Contact Person – Melissa Sparks, Superintendent Corrective Action Plan – The District staff will work with the construction manager to ensure wage rates requirements are monitored. Completion Date – June 2025

View Audit 343854

Finding 524483 (2024-003)

Significant Deficiency 2024

Town of Middlebury, Vermont

VT

Cash Management Matching / Level of Effort / Earmarking

Recommendation: Request reimbursement of loans throughout the project.

View Audit 343825

Finding 524468 (2024-001)

Significant Deficiency 2024

The Colleges of Law

CA

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Feder...

Corrective Action Plan – The Colleges of Law Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: The College had one instance of excess cash for the Federal Direct Student Loan program, ranging from $172 to $10,314, from March 25, 2024, to April 5, 2024. Although the excess cash did not exceed the one-percent tolerance of prior year drawdowns, the funds were not returned within the required seven-day period. Summary: The College inadvertently retained excess cash for the Federal Direct Student Loan program beyond the seven-day tolerance period due to administrative oversight. The delay in returning the excess cash was attributed to the reconciliation process taking longer than anticipated. Corrective Action Planned or Taken: 1. Procedure Update: The College has updated its cash management procedures to ensure excess funds are returned to the Secretary within the seven-day tolerance period. 2. Process Change: The College will enhance its reconciliation process to expedite the identification and return of excess cash within the required timeframe. 3. Internal Control Strengthening: The College will implement more rigorous internal controls, including automated alerts and checks, to ensure compliance with cash management requirements. 4. Staff Training: Relevant staff will receive additional training on updated cash management procedures and the importance of timely returning excess cash. 5. Improved Monitoring: The College will introduce enhanced monitoring and tracking mechanisms to ensure that excess cash is promptly identified and returned within the mandated period. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343821

Finding 524441 (2024-001)

Significant Deficiency 2024

McDaniel College and Subsidiary

MD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Y...

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25

View Audit 343760 Questioned Costs: $1

Finding 524440 (2024-002)

Material Weakness 2024

The Housing Authority of the City of Warner Robins

GA

HUD Housing Programs Material Weakness Matching / Level of Effort / Earmarking

The Authority will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. The Authority’s Executive Director, Africa Porter, has assumed the responsibility of executing this corrective action as of April 1, 2025.

View Audit 343759

Finding 524434 (2024-003)

Significant Deficiency 2024

Payne Theological Seminary

OH

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

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The seminary will update our current WISP to comply with all requirements and updated standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram Planned completion date for corrective action plan: April 2025

View Audit 343723

Finding 524433 (2024-002)

Significant Deficiency 2024

Payne Theological Seminary

OH

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

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary implemented a process to ensure credit balances are returned timely based on the regulations set forth by the Department of Education. Explanation of disagreement with audit finding: There is no disagreeme...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary implemented a process to ensure credit balances are returned timely based on the regulations set forth by the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Through December 2024, Payne issues credits/refunds in two disbursements. In November 2024, the Business Office and Academic Services discussed moving to a single credit/refund disbursement in an effort to avoid potential delays in processing. A decision was made to approve the single credit/refund disbursement process effective Spring 2025. Financial Aid Services was notified and provided a new disbursement schedule. Communication of the change was sent to students November 30, 2024. Person responsible - Maryjo Lewis Planned completion date: The new process in effect beginning Spring 2025 term

View Audit 343723

Finding 524432 (2024-001)

Significant Deficiency 2024

Payne Theological Seminary

OH

Student Financial Aid Reporting Significant Deficiency

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding:...

Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend the Seminary evaluate its procedures and policies around reporting Unsubsidized loan disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Business Office will post the awarded funds to the accounts in SONIS on the date designated on the disbursement roster. Name(s) of the contact person(s) responsible for corrective action: Razieh Adinehzadeh Planned completion date for corrective action plan: Changes implemented in February 2025.

View Audit 343723

Finding 524425 (2024-001)

Significant Deficiency 2024

Morehouse College

GA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding No. 2024-001 SFA – Enrollment Reporting Federal Program Student Financial Assistance Cluster AL No. 84.268 Federal Direct Student Loans Federal Agency U.S. Department of Education Federal Award Years October 1, 2022 to September 30, 2023 October 1, 2023 to September 30, 2024 Criteri...

Finding No. 2024-001 SFA – Enrollment Reporting Federal Program Student Financial Assistance Cluster AL No. 84.268 Federal Direct Student Loans Federal Agency U.S. Department of Education Federal Award Years October 1, 2022 to September 30, 2023 October 1, 2023 to September 30, 2024 Criteria or Requirement Institutions are required to report enrollment information under the Pell grant and the Direct and FFEL loan programs via the NSLDS (OMB No. 1845-0035) (Pell, 34CFR 690.83(b)(2); FFEL, 34CFR 682.610; Direct Loan, 34 CFR 685.309; Perkins 34 CFR 674.19(f)). Condition and Context During our test work, we selected a sample of 40 students that had enrollment status changes during fiscal year 2024. Within our sample, we identified 3 instances where the students’ enrollment status was not properly communicated to National Student Loan Data System (NSLDS). These instances involved students who reported their status changes to the College after the normal reporting period had ended. Cause and Potential Effect Noncompliance due to no control in place to identify late submissions of status changes and ensure that these changes are properly communicated to the NSLDS. This lack of control could result in inaccurate or delayed reporting of student status changes to the NSLDS, potentially affecting loan servicing and compliance with federal regulations. Questioned Cost There were no questioned cost associated with the finding. Corrective Action Plan to Finding 2024-001: Contact person for corrective action: LaKeidra Gilford – Interim Registrar Office of Records and Registration Corrective Action Plan: Morehouse College plan to implement the following to address finding No. 2024-001. • Office of Records and Registration will create a new policy effective July 1, 2025, that will state any medical withdrawals received after the last day of the current term will not be honored. • Office of Records and Registration effective May 2025 will continue the current process with additionally submitting two (2) additional graduation reports each month after the initial report is sent to National Student Clearinghouse to ensure all graduates are captured and reported.

View Audit 343696

Finding 524389 (2024-001)

Significant Deficiency 2024

Kansas Health Science Center, Inc.

IL

Student Financial Aid Cash Management Matching / Level of Effort / Earmarking § 200.303

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, oth...

Corrective Action Plan – Kansas Health Science University Identifying Number: 2024-001 Finding: Excess Cash – Student Financial Aid Applicable Regulation: According to Uniform Grant Guidance (34 CFR 668.166), the Secretary considers excess cash to be any amount of Title IV, HEA program funds, other than Federal Perkins Loan program funds, that an institution does not disburse to students within the required timeframe. Institutions must return any amount of excess cash over the one-percent tolerance and any remaining cash after the seven-day tolerance period. Finding: Kansas Health Science University (KHSU) had excess cash for the Federal Direct Student Loan program, including $268,278 from July 12, 2023, to July 19, 2023, and amounts ranging from $2,204 to $13,385 from April 8, 2024, to April 23, 2024. For the first period, the excess cash exceeded the one-percent tolerance of prior year drawdowns and was not returned within the three business-day period. For the second period, although the excess cash did not exceed the one-percent tolerance, amounts were not returned within the seven-day period as required. Summary: KHSU identified two instances of excess cash due to delays in returning unused funds. The Funds were not returned to ED withing the required number of days, leading to a violation of the federal cash management requirements. The issue was related to an administrative oversight related to the timing of the return of drawn funds. Corrective Action Planned or Taken: 1. Procedure Update: KHSU will update its cash management procedures to ensure compliance with both the three-day and seven-day return requirements for excess cash. 2. Process Change: KHSU will implement a process to immediately review and reconcile drawdowns with disbursement needs. Drawdowns will be based strictly on reconciled disbursement schedules to prevent excess cash. 3. Internal Control Strengthening: Internal controls will be enhanced to include automated alerts for identifying excess cash and triggering prompt corrective actions. 4. Staff Training: Financial aid and accounting staff will undergo targeted training on Federal cash management regulations, focusing on the prevention and timely resolution of excess cash. 5. Improved Monitoring: KHSU will establish daily monitoring of cash balances during peak disbursement periods and periodic reviews to ensure ongoing compliance with Federal regulations. Contact Person: Theresa Cowan, Associate Vice President, Compliance and Student Finance tcowan@tcsedsystem.edu Anticipated Completion Date: December 16, 2024

View Audit 343627

Finding 524387 (2024-002)

None 2024

Tongue River Valley Joint Powers Board

WY

Matching / Level of Effort / Earmarking

2024-002 Loan Requirement Non-Compliance The Chairman of the Tongue River Valley Joint Powers Board will continue to work with USDA-RD to find ways to address this issue. The Board and the USDA are looking to sell Tongue River Gas to a third party or put it up for auction in the near future.

View Audit 343621

Finding 524369 (2024-001)

None 2024

Chowan University

NC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Richard Todd, Registrar & Ruth Casper, Assistant Vice President of Student Financial Services Corrective Action: The University Financial Aid Office will work alongside the Registrar’s Office to identify and correct any enrollment reporting errors which may arise. Co...

Name of Responsible Individual: Richard Todd, Registrar & Ruth Casper, Assistant Vice President of Student Financial Services Corrective Action: The University Financial Aid Office will work alongside the Registrar’s Office to identify and correct any enrollment reporting errors which may arise. Corrections may include subsequent reporting to the Clearinghouse and/or manual reporting to NSLDS. Anticipated Completion Date: Ongoing

View Audit 343592

Finding 524368 (2024-004)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 22611-048-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for the participating memb...

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) - Earmarking Summary of Finding: The Non-Public Proportionate Share expenditures for the 22611-048-PN01 grant award could not be verified for the individual member schools. The non-public school share funds for the participating member schools were allocated based on the yearly budget for certified staff instead of time charged to the non-public schools. These allocations were the amounts reported to IDOE. As such, we were unable to identify which expenditures were for each school in order to verify the minimum amount per the grant award was expended and properly reported to IDOE as required. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us INDIANA STATE BOARD OF ACCOUNTS 27 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Expenses for non-public schools are tracked and charged to the appropriate corporation. Staff record time spent at each non-public school, sign and date the form and turn it into the treasurer. The expenses are then moved to the correct expense line on the grant after receiving this information. Materials that are purchased are charged to the correct expense account when paid. Anticipated Completion Date: July 1, 2023

View Audit 343584

Finding 524366 (2024-003)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

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

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were ...

FINDING 2024-003 Finding Subject: Education Stabilization - Reporting Summary of Finding: The School Corporation had not designed, nor implemented, a system of internal controls to ensure that the annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports (Reports) were complete and accurately submitted. The Reports were prepared by one employee without a documented oversight, review, or approval process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for and will keep documentation of the review being done and signed off on. Anticipated Completion Date: This will be corrected with the next round of ESSER reporting due January 2025.

View Audit 343584

Finding 524362 (2024-002)

Material Weakness 2024

Jac-Cen-Del Community School Corporation

IN

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

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) – Internal Controls Summary of Finding: The Indiana Department of Education calculates the Maintenance of Effort - Level of Effort based on expenditure information submitted on the Form 9 for that fiscal year. The Treasurer was respo...

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) – Internal Controls Summary of Finding: The Indiana Department of Education calculates the Maintenance of Effort - Level of Effort based on expenditure information submitted on the Form 9 for that fiscal year. The Treasurer was responsible for the preparation and submission of the Form 9. There were no documented internal controls in place such as an oversight, review, or approval process to ensure expenditures were correctly reported. Contact Person Responsible for Corrective Action: Trina Huff Contact Phone Number and Email Address: (812) 689-4114, thuff@jaccendel.k12.in.us Views of Responsible Officials: We concur with the finding 􀁹􀈱EVERY􀈱CHILD􀈱􀁹􀈱EVERY􀈱CHANCE􀈱􀁹􀈱EVERY􀈱DAY􀈱􀁹 JAC􀈬CEN􀈬DEL􀈱COMMUNITY􀈱SCHOOLS CENTRAL OFFICE HIGH SCHOOL / ATHLETICS ELEMENTARY SCHOOL 723 N Buckeye Street 4586 N US 421 4544 N US 421 Osgood, Indiana 47037 Osgood, Indiana 47037 Osgood, Indiana 47037 Telephone: (812) 689-4114 Telephone: (812) 689-4643 Telephone: (812) 689-4144 www.jaccendel.k12.in.us Fax: (812) 689-7423 Fax: (812) 689-5632 Fax: (812) 689-5909 INDIANA STATE BOARD OF ACCOUNTS 26 Description of Corrective Action Plan: Moving forward treasurer will provide even more information to the reviewer specifically pertaining to the findings and any other pertinent information for that person to have a better idea of what they are looking for. I actually printed the Form 9 transmittal report that has the accounts and amounts on it and had the Superintendent review it and sign off on it for the December 2024 Form 9. This will be our process moving forward. Anticipated Completion Date: With the completion of the most recent form 9 December 31, 2024.

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