Corrective Action Plans

Finding 390408 (2023-004)

Material Weakness 2023

AZ

Questioned Costs Material Weakness Reporting

Finding Number: 2023‐004 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Faron Logan, Business Manager Anticipated Completion Date: April 30, 2024 Planned Corrective Action: The Business Manager will imme...

Finding Number: 2023‐004 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425U Contact Person: Faron Logan, Business Manager Anticipated Completion Date: April 30, 2024 Planned Corrective Action: The Business Manager will immediately ensure that all payroll withholdings/ deductions will be processed properly along with all stipends. This will correct the quarterly Form 941 that will be filed by the Business Manager. All time sheets will be reviewed by Business Manager to make sure all employees hours are correctly paid.

View Audit 301207

Finding 390273 (2023-006)

Material Weakness 2023

Commonspirit Health

IL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radi...

REFERENCE: 2023-006 – Reporting – Common Origination and Disbursement (COD) System Student Financial Assistance Cluster (Assistance Listing Nos. 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science did not perform its internal control over the requirement to submit Pell and Direct Loan origination and disbursement records to the Department of Education through the COD system, which consists of monthly COD reconciliations. CHI Health School of Radiologic Technology does not have a process in place for updating the COD system for actual disbursement dates. The COD disbursement information reported by CHI Health School of Radiologic Technology was based on “assumed” and “expected” disbursement dates and amounts, but is never updated for actual disbursement dates. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management for presentation to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will review their processes to develop and implement internal controls that ensure compliance with federal regulations. Evidence of the internal control being performed will be retained. Person Responsible: Judy Kronenberger, President Good Samaritan College of Nursing and Health Science and Financial Aid Services (FAS) David Velasquez, Nuclear Medicine Technologist Coordinator (CHI Health School of Radiologic Technology) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390270 (2023-005)

Material Weakness 2023

Commonspirit Health

IL

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

REFERENCE: 2023-005 – Cash Management Student Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samar...

REFERENCE: 2023-005 – Cash Management Student Financial Assistance Cluster (Assistance listing No. 84.007, 84.063, 84.268) Federal Grantor: U.S. Department of Education Facility: Good Samaritan College of Nursing and Health Science and CHI Health School of Radiologic Technology Finding: Good Samaritan College of Nursing & Health Science has processes in place for determining the amount of student financial aid to be drawn down and disbursed; however, management did not perform internal controls over cash management throughout the year. CHI Health School of Radiologic Technology has processes in place for determining the amount of Direct Loans and Pell grants to be drawn down and disbursed; however, there is no review control in place over the disbursement amounts before funds are drawn down from the G5 system. Corrective Action Plan: This finding has been corrected for Good Samaritan. In May of 2023, for April 2023 data, Good Samaritan implemented a formal monthly reconciliation process, including comparison of all systems for the period, a final review of G5 funds prior to draw down, a cover sheet noting any explaining any differences, proper sign off for preparation and review and the date by Good Samaritan management and FAS management. This review is presented monthly to the Compliance Oversight Committee. A year end reconciliation is also performed following the same process. CHI Health School of Radiologic Technology will implement a review control for accounting staff to review the draw down amount provided by the School prior to completing the drawn down. Documentation of the review will be retained. Person Responsible: Judy Kronenberger, President, Good Samaritan College of Nursing and Health Science and Andrea Heffelfinger, Market Director of Accounting (CHI Health) Completion/Expected Completion: April 2023 (Good Samaritan)/June 2024 (CHI Health School of Radiologic Technology)

View Audit 301158

Finding 390235 (2023-002)

Material Weakness 2023

National University

CA

Student Financial Aid Material Weakness Reporting

Finding 2023-002 - Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control Management agrees with this finding. The institution proposes a multifaceted approach aimed at resolving the root causes of the inaccuracies and preventing their recurrence. National Univer...

Finding 2023-002 - Special Tests and Provisions – Enrollment Reporting: Material Weakness in Internal Control Management agrees with this finding. The institution proposes a multifaceted approach aimed at resolving the root causes of the inaccuracies and preventing their recurrence. National University has implemented regular reviews of its enrollment reporting. During this process, errors in reporting are identified and corrected. However, the timing of the review has not allowed enough time to process corrections within compliance. To allow for appropriate adjustments and corrections to be implemented after testing but before the enrollment reporting deadline, National University will shift the timing of its enrollment reporting review from 60 to 30 days. Though NU is currently testing enrollment reporting and adjusting queries in an ongoing effort to improve accuracy, some of those adjustments inadvertently caused students to not appear in our queries. This impact on reporting occurred in edge cases not taken into account in the queries. To ensure this does not happen in the future, NU will implement a testing regime for these queries. This testing will be conducted at regular intervals to verify the effectiveness and accuracy of the queries in identifying students who have ceased attendance as required. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. We know that these efforts will take time to fully take effect and be reflected in future audits. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance and Sarah Massey, AVP Operations, Student Support and Registrar Anticipated Completion Date: June 2024

View Audit 301132

Finding 390234 (2023-001)

Material Weakness 2023

National University

CA

Internal Control / Segregation of Duties Questioned Costs Special Tests & Provisions

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we c...

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. Finding 2023-001 - Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University agrees with this finding. As we continue to refine our R2T4 processes, we’ve had two key challenges we are addressing: Timeliness of R2T4 calculations: In FY22, NU identified an issue with how it was identifying unofficial withdrawals at the institution. To assist in rectifying the issue, we implemented a 35-day attendance policy that resulted in a significant amount of students being attritted from the University. We were working with a third-party firm to help us complete all the R2T4 calculations, which proved challenging; between our internal staffing and external support, we did not have the ability to do all of the calculations timely. As we’ve analyzed the needed manpower, we’ve expanded our Processing and Quality Assurance teams. The establishment of two additional teams within the Processing team in 2024 underscores our commitment to ensuring the timely completion of necessary calculations. Simultaneously, the increased Quality Assurance team is poised to support the enhanced internal controls, conducting weekly reviews of R2T4 calculations to verify their accuracy and timeliness. Missing students for R2T4 calculations who were withdrawn: We have established precise and accurate criteria for the development and execution of report queries. This initiative aims to ensure the comprehensive identification of students who discontinue attendance before the end of a payment period, thereby mitigating the risk of oversight. To bolster the reliability of these refined processes, NU is committed to implementing regular testing of the attendance queries. By conducting these tests at established intervals, the institution seeks to verify that the queries consistently identify the correct cohort of students. This approach serves as a crucial mechanism to maintain the accuracy of our withdrawal determination processes and underscores our dedication to continuous improvement. Through these concerted efforts, NU hopes to demonstrate its full commitment to addressing the audit findings. We know that these efforts will take time to fully take effect and be reflected in future audits. Contact Person Responsible for Corrective Action: Brandy Baker, Director of Quality Assurance Angela De Angelini, AVP Processing and Fiscal Operations Anticipated Completion Date: June 2024

View Audit 301132

Finding 390225 (2023-001)

Material Weakness 2023

Do Good Multnomah

OR

Internal Control / Segregation of Duties Questioned Costs Allowable Costs / Cost Principles

The finance team has been expanded and with the guidance of a nonprofit finance consultant additional roles are set to be established so that there is support to be able to be able to adequately review and approve invoices, as well as train and hold accountability with supervisors for payroll approv...

The finance team has been expanded and with the guidance of a nonprofit finance consultant additional roles are set to be established so that there is support to be able to be able to adequately review and approve invoices, as well as train and hold accountability with supervisors for payroll approval.

View Audit 301123

Finding 390219 (2023-004)

Material Weakness 2023

Enlace Chicago

IL

Questioned Costs Procurement, Suspension & Debarment Eligibility

Procurement Recommendation: We recommend that the Organization follow the current policies and procedures over covered transactions to maintain documentation supporting the procurement for 5 years following the end of the contract. Views of Responsible Officials: There is no disagreement with this ...

Procurement Recommendation: We recommend that the Organization follow the current policies and procedures over covered transactions to maintain documentation supporting the procurement for 5 years following the end of the contract. Views of Responsible Officials: There is no disagreement with this finding. Action taken in response to finding: Enlace Chicago is committed to following the procurement process and requirements outlined within the policies and procedures. Name of the contact person responsible for corrective action: Laura Velazquez, Director of Finance Planned completion date for corrective action plan: June 30, 2024.

View Audit 301111

Finding 390194 (2023-001)

Material Weakness 2023

College Dreams, INC

OR

Allowable Costs / Cost Principles Cash Management Material Weakness

Finding # 2023-001 Material weakness over allowable costs U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: Only allowable costs may be charged to the contract for reimbursement. One out of six invoices charged to the contract was an unallowable expense (sc...

Finding # 2023-001 Material weakness over allowable costs U.S. Department of Education 84.044A TRIO Programs Cluster: TRIO – Talent Search Finding: Only allowable costs may be charged to the contract for reimbursement. One out of six invoices charged to the contract was an unallowable expense (scholarships). Recommendation: Expenses charged to contract should be reviewed thoroughly and be in compliance with contract agreement. Management should have understanding of what costs are considered allowable and unallowable. Corrective Action: We will have the Executive Director, Business Manager and College+ Program Manager thoroughly review the monthly Talent Search billing before completing a drawdown to ensure that all expenses billed are allowable costs. Anticipated Completion Date: June 30, 2024

View Audit 301101

Finding 390168 (2023-002)

Material Weakness 2023

Altus Independent School District #18

OK

Questioned Costs Subrecipient Monitoring Material Weakness

Altus Public Schools plans to meet the requirements of the Davis-Bacon Act on any future federal awards. Weekly payroll reports will be reviewed with vendors to ensure that federal rates and fringes are met. Items will be posted at the work site to ensure compliance with the Davis-Bacon Act.

View Audit 301082

Finding 390167 (2023-001)

Material Weakness 2023

Altus Independent School District #18

OK

Questioned Costs Subrecipient Monitoring Material Weakness

Altus Public Schools plans to meet the requirements of the Davis-Bacon Act on any future federal awards. Weekly payroll reports will be reviewed with vendors to ensure that federal rates and fringes are met. Items will be posted at the work site to ensure compliance with the Davis-Bacon Act.

View Audit 301082

Finding 390165 (2023-006)

Material Weakness 2023

Yukon Flats School District

AK

Allowable Costs / Cost Principles Questioned Costs Material Weakness

Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Management will ensure that the system of internal controls over cash disbursements is designed appropriately and operates effectively to ensure all transactions are coded, reviewed, and approved before payment is mad...

Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Management will ensure that the system of internal controls over cash disbursements is designed appropriately and operates effectively to ensure all transactions are coded, reviewed, and approved before payment is made. The Business manager and the Superintendent will conduct a review of claims to determine whether they are proper and valid charges. Once reviewed, all transactions will be authorized. DocuSign will be used for electronic signature approval. Accounts payable clerk will ensure that all transactions include copies of receipts for the goods or services purchased. Finally, the Finance department will work with the program directors to ensure that expenses are coded accurately and within reasonable timeframe to allow for timely submission of grant reports. Proposed Completion Date: March 31, 2024

View Audit 301080

Finding 390163 (2023-005)

Material Weakness 2023

Yukon Flats School District

AK

Questioned Costs Cash Management Material Weakness

Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD hired an experienced and independent contract grants specialist. She is using Outlook to set up reporting reminders to ensure timely submission of reports. In addition, the Business office started using a calenda...

Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD hired an experienced and independent contract grants specialist. She is using Outlook to set up reporting reminders to ensure timely submission of reports. In addition, the Business office started using a calendar developed by ALASBO which addresses all reporting requirements for the school districts in Alaska. Proposed Completion Date: March 31, 2024

View Audit 301080

Finding 390146 (2023-002)

Material Weakness 2023

Health Care for All, INC

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Given the Organization’s lack of experience with federal awards, Management was not familiar with the accounting requirements for expenses allocated to federal grant programs. In particular, there was a lack of familiarity with respect to the limitations on indirect cost rate application on subreci...

Given the Organization’s lack of experience with federal awards, Management was not familiar with the accounting requirements for expenses allocated to federal grant programs. In particular, there was a lack of familiarity with respect to the limitations on indirect cost rate application on subrecipient disbursements. Moving forward, management will ensure that it properly allocate expenses in accordance with Uniform Guidance Regulations. In addition, management plans to work closely with the federal passthrough entity to ensure that overbilled amounts are returned during the fiscal year ending June 30, 2024

View Audit 301052 Questioned Costs: $1

Finding 390138 (2023-002)

Material Weakness 2023

Barnes-Kasson County Hospital

PA

Questioned Costs Material Weakness Reporting § 200.303

Finding 2023-002 Condition The Hospital did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the Hospital erroneously entered information into the lost revenue calculation, resulting in lost revenues being understated $1,020,0...

Finding 2023-002 Condition The Hospital did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. We noted that the Hospital erroneously entered information into the lost revenue calculation, resulting in lost revenues being understated $1,020,030. The Hospital reported lost revenues amounting to $999,172 on distributions totaling $1,177,041. The Hospital had excess lost revenues from previous periods available to be used through June 30, 2023 amounting to $5,406,884. The Hospital also reported expenses of $907,051. Corrective Action Plan Corrective Action Planned: The Hospital will undertake a review of its internal control policies and procedures surrounding the reporting on federal grant activities and add additional layers of review where necessary to ensure future reporting is accurate. Name of Contact Person Responsible for Corrective Action: Kelli Kane, Chief Financial Officer Anticipated Completion Date: April 15, 2024

View Audit 301031

Finding 390136 (2023-001)

Significant Deficiency 2023

Northeast Colorado Board of Cooperative Educational Services

CO

Cash Management Subrecipient Monitoring Material Weakness § 200.305

Management Response: The BOCES will assure internal control procedures are in place to verify that all grant funding requests meet Cash Management requirements. Reimbursements will be requested subsequent to the expenditure of grant funds. The BOCES will establish internal controls whereby the gran...

Management Response: The BOCES will assure internal control procedures are in place to verify that all grant funding requests meet Cash Management requirements. Reimbursements will be requested subsequent to the expenditure of grant funds. The BOCES will establish internal controls whereby the grant manager determines the amount to be requested and this will be subsequently verified by finance staff to ensure that total requests do not exceed incurred or obligated expenditures. A review of the internal control procedures with all grant management and finance staff will assure that this is not a reoccurring issue.

View Audit 301027

Finding 390126 (2023-003)

Material Weakness 2023

San Francisco Community College District

CA

Allowable Costs / Cost Principles Student Financial Aid Subrecipient Monitoring § 200.430

The district Information Technology Services unit is currently working with Ellucian to configure and implement the Time and Effort reporting module within the BANNER timekeeping system. This will allow departments to monitor time and effort activity and ensure that allowable costs are tracked and c...

The district Information Technology Services unit is currently working with Ellucian to configure and implement the Time and Effort reporting module within the BANNER timekeeping system. This will allow departments to monitor time and effort activity and ensure that allowable costs are tracked and charged to the appropriate programs and services. This should be completed by June 30, 2024.

View Audit 301013

Finding 390069 (2023-004)

Material Weakness 2023

Gulf Coast Jewish Family and Community Services, INC

FL

Questioned Costs Reporting Material Weakness § 200.502 § 200.510

Management has reviewed the recommendations and will review current and implement new procedures and controls to ensure that all post- award notices received from funding agencies are properly incorporated into the Schedule. Additionally, Management will review reconciliation procedures, and impleme...

Management has reviewed the recommendations and will review current and implement new procedures and controls to ensure that all post- award notices received from funding agencies are properly incorporated into the Schedule. Additionally, Management will review reconciliation procedures, and implement internal controls around the Schedule reconciliation process back to the consolidated financial statements. The corrective action will be implemented no later than June 30, 2024. The primary designated official is Chief Financial Officer.

View Audit 300946 Questioned Costs: $1

Finding 390061 (2023-003)

Material Weakness 2023

Ohio Medical Transportation, Inc. D/b/a Medflight of Ohio

OH

Questioned Costs Material Weakness Reporting

Finding Number: 2023-003 Condition: The Corporation reported the incorrect amount of lost revenues for the period 4 portal submission for MedFlight. Planned Corrective Action: Management agrees and ...

Finding Number: 2023-003 Condition: The Corporation reported the incorrect amount of lost revenues for the period 4 portal submission for MedFlight. Planned Corrective Action: Management agrees and has revised existing internal control processes and policies to implement review and approval procedures to ensure data uploaded into the portal agrees to underlying supporting documentation. Contact person responsible for corrective action: Joe Abel, Chief Financial Officer Anticipated Completion Date: 4/30/2023

View Audit 300923

Finding 389980 (2023-001)

Material Weakness 2023

Amber-Pocasset School District I-128

OK

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Beginning immediately the District will develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and frin...

Beginning immediately the District will develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. The District will also ensure that all items are posted at the work site to ensure compliance.

View Audit 300880

Finding 389897 (2023-001)

Material Weakness 2023

Wide Ruins Community School

AZ

Allowable Costs / Cost Principles Questioned Costs Procurement, Suspension & Debarment

Finding Number: 2023‐001 Program Names/Assistance Listing Titles: Indian School Equalization, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations and Maintenance Assistance Listing Numbers: 15.042, 15.046, 15.047 Contact Person: Stephanie Woody, Business Technician...

Finding Number: 2023‐001 Program Names/Assistance Listing Titles: Indian School Equalization, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations and Maintenance Assistance Listing Numbers: 15.042, 15.046, 15.047 Contact Person: Stephanie Woody, Business Technician; Aurelia Tapaha, Business Manager/Human Resource Manager; Jeannie Lewis, Principal Anticipated Completion Date: July 2024 Planned Corrective Action: The School will review the procurement flowcharts and required documents for Business Technician. The School will obtain training for chart of accounts training for business staff along with procurement training. Business staff and administrators will keep abreast of law changes, GASB updates, and budget changes with grants received. The School will review school credit and implement a timeframe where the no use of the credit card is enforced. The School will collect all required documents to process payments. The entire balance will be paid in full amount for each month. Training on use of credit cards will be given during orientation.

View Audit 300789

Finding 389896 (2023-001)

Material Weakness 2023

Monongalia County Urban Mass Transit Authority

WV

Subrecipient Monitoring Questioned Costs Matching / Level of Effort / Earmarking § 200.334

The party that was making sure of signatures and signatures of changes ended up in a backlog and lost time cards. If time cards are sent back for signatures a copy of the original will be kept until the signed ones come back, and follow up will be made on a timely basis.

View Audit 300786 Questioned Costs: $1

Finding 389887 (2023-001)

Material Weakness 2023

Kayenta Unified School District No.27

AZ

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Arlene Laughter, Business Supervisor Anticipated Completion Date: December 31, 2024 Planned Correctiv...

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Arlene Laughter, Business Supervisor Anticipated Completion Date: December 31, 2024 Planned Corrective Action: The District has created an assistant manager position that will oversee all mandatory and required reports as requested by the Department of Education and Grants management. The District has also reached out to Jon Chase with Grants management to determine the required status of the report. In the future, the District will create a calendar to determine all timelines are met.

View Audit 300772

Finding 389878 (2023-002)

Material Weakness 2023

Tusculum University

TN

Questioned Costs Student Financial Aid Subrecipient Monitoring

2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the Designated Employees in charge of overseeing the GLBA polic...

2023-002 Material Weakness: Gramm-Leach-Bliley Act (GLBA) (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) Name of Contact Person Casey Reagan, Registrar, and Chris Summey, Head of our IT Department, are the Designated Employees in charge of overseeing the GLBA policy. Corrective Action Planned During the audit, it was noted that Tusculum did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University for the 2023 year. In fall 2023, IT, the Registrar, and the Director of Financial Aid met to discuss making sure that all of the new pieces of the GLBA policy were being implemented properly. In December of 2023, IT began the latest vulnerability scan and risk assessment to be in compliance with the risk assessment requirements of the GLBA Policy. This assessment should be completed by the end of spring 2024. The University is also working on updating its GLBA policies and procedures to align with the GLBA Policy. Anticipated Completion Date This process is currently ongoing and it is the University's goal to have ongoing GLBA policies updated and the risk assessment completed before the end of the 2023-2024 academic year.

View Audit 300763

Finding 389779 (2023-002)

Material Weakness 2023

Antioch College Corporation

OH

Procurement, Suspension & Debarment Material Weakness Matching / Level of Effort / Earmarking

Finding 2023-002 - Material Weakness - Borrowings from Endowment Fund Condition Found The College has borrowed from its endowment funds for campus renovations and to cover certain operating expenses of the College prior to and following its accreditation and approval to participate in federal studen...

Finding 2023-002 - Material Weakness - Borrowings from Endowment Fund Condition Found The College has borrowed from its endowment funds for campus renovations and to cover certain operating expenses of the College prior to and following its accreditation and approval to participate in federal student financial aid programs. As such, the fair value of assets associated with the donor-restricted endowment funds has fallen below the level that the donor or UPMIFA requires the College to retain as a fund of perpetual duration. Corrective Action Plan The College obtained guidance from legal counsel regarding the appropriateness of borrowing from the endowment fund under Ohio UPMIFA. The College has developed long-term plans for maintaining and sustaining its financial stability, including restoration of the endowment, through the following strategies outlined in the board-approved Social Enterprise and Enrollment Plan: ● Grow advancement-derived revenue ● Implement core college footprint ● Align student-derived revenue ● Activate learning hubs ● Explore potential game changers, such as the College’s recent Federal Work College designation ● Assess non-payroll cost reduction strategies ● Invest in additional capacity incrementally ● Monitor performance, evaluate results, and course-correct as needed Responsible Person for Corrective Action Plan Jane Fernandes, President

View Audit 300675

Finding 389778 (2023-001)

Material Weakness 2023

Antioch College Corporation

OH

Material Weakness Reporting Internal Control / Segregation of Duties

Finding 2023-001 - Material Weakness - Required Material Adjustments Condition Found There were insufficient internal controls over financial reporting requiring material audit adjustments during the audit to prevent the financial statements from being materially misstated. Corrective Action Plan In...

Finding 2023-001 - Material Weakness - Required Material Adjustments Condition Found There were insufficient internal controls over financial reporting requiring material audit adjustments during the audit to prevent the financial statements from being materially misstated. Corrective Action Plan In September 2024, Antioch College contracted with the firm Dean Dorton Allen Ford, PLLC to provide Accounting and Financial Outsourcing services, filling and stabilizing the controller/CFO function. With their accounting expertise, the College has restructured accounting procedures to ensure reliable internal financial reporting including an improvement in accounting systems. The College is also focusing on additional traning for finance staff , streamlining financial reporting processes, and following internal controls. Responsible Person(s) for Corrective Action Plan Jane Fernandes, President Hannah Montgomery, Director of Operations and Administration

View Audit 300675

Corrective Action Plans

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