Corrective Action Plans

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Finding 2024-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended December 31, 2024, management did not properly accrue federal grant expenditures that were incurred during the fourth quarter of fiscal year 2024. As a result, federal grant expenses on...
Finding 2024-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended December 31, 2024, management did not properly accrue federal grant expenditures that were incurred during the fourth quarter of fiscal year 2024. As a result, federal grant expenses on cost reimbursement grants and related revenues were understated as of December 31, 2024, and required year end audit adjustments to properly reflect expenditures incurred but not invoiced or recorded as of year end. Recommendation We recommend that individuals overseeing the accounting and finance department continue to review the Organization’s current accounting policies and update existing policies or implement new policies, as needed, to ensure that federal grant expenditures are accrued for and recorded in the proper period and reconciliations between incurred expenditures, invoices submitted and amounts recorded in the general ledger are completed and reviewed monthly or quarterly, as appropriate. Management’s Corrective Action Plan Management is working to improve the timeliness of reconciliations and has implemented procedures to identify and accrue grant expenditures incurred but not yet invoiced at period end, as needed. Management will perform periodic reconciliations between incurred expenditures, invoices submitted to grantors, and amounts recorded in the general ledger, and will ensure such reconciliations are reviewed and approved by the appropriate personnel. Management is confident that the issues that have been noted have been rectified. Contact Person: Patricha Paul, Finance Director Anticipated Completion Date: June 30, 2026
2024-003: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Noncompliance, Material Weakness Condition: The school lacked adequate internal controls over its accounting disbursements to ensure that a) all financial activities were properly processed and recorded and b...
2024-003: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Noncompliance, Material Weakness Condition: The school lacked adequate internal controls over its accounting disbursements to ensure that a) all financial activities were properly processed and recorded and b) the School remained in compliance with federal requirements. Context: During our review of the school’s accounting records and internal controls, as well as through management inquiry, we noted the following: • For two of 25 accounts payable transactions tested out of the 15.044 grant, the School did provide adequate documentation to support the allowability of the expenditure. • For three of 25 accounts payable transactions tested out of the 15.046 grant, the School did provide adequate documentation to support the allowability of the expenditure. Repeat Finding: Repeated and modified. Action planned in response to the finding: The Principal will conduct an internal review of records management practices to verify that all accounts payable disbursements are properly supported. This evaluation will include random checks of purchase orders and their complete supporting documentation, once per month, to ensure accuracy, compliance, and integrity in financial operations. Keep all documents audit ready, at all times. Planned completion date for a corrective action plan: June 30, 2025 Name of the contact person responsible for corrective action: Marie Rose, Principal | Lynnette Greyeyes, Business Manager
2024-004: Reporting Type of Finding: Noncompliance, Material Weakness Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted May 1, 2026, which was 396 days past the March 31, 2025 deadline. Action plan in response to the finding: The Pr...
2024-004: Reporting Type of Finding: Noncompliance, Material Weakness Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted May 1, 2026, which was 396 days past the March 31, 2025 deadline. Action plan in response to the finding: The Principal will ensure that all required audit documentation is organized, complete, and readily available to the auditors upon request. This includes maintaining updated financial records, supporting documents, reconciliations, and schedules throughout the fiscal year so that materials can be provided promptly during the audit process. To support timely completion of the annual audit, the Principal will formally request the 2025 audit to be completed by August 30, 2026. This timeline allows adequate opportunity for fieldwork, review, and finalization of the audit report. The Principal will monitor progress, respond quickly to auditor inquiries, and verify that the final audit report is submitted within the required timeframe. The 2026 Audit Request for Proposal will be submitted at the End of April 2026 for School Board approval. Repeat Finding: No. Planned completion date for a corrective action plan: June 30, 2026 Name of the contact person responsible for corrective action: Marie Rose, Principal | Lynnette Greyeyes, Business Manager
Views of Responsible Officials and Planned Corrective Actions The Organization’s management is aware of this material weakness and has considered adding additional personnel to assist in the monthly reconciliations and financial statement preparation. Management reviews and approves the monthly inte...
Views of Responsible Officials and Planned Corrective Actions The Organization’s management is aware of this material weakness and has considered adding additional personnel to assist in the monthly reconciliations and financial statement preparation. Management reviews and approves the monthly interim financial statements and uses the knowledge that management and the Board of Directors has of operations by having them review certain accounting records and reports. Also, management monitors the effectiveness of the above actions and makes changes as considered appropriate.
Duplicate Payments to Vendors Condition Duplicate vendor payments occurred due to inadequate segregation of duties and inconsistent invoice naming conventions. Corrective Action Plan The Accounts Payable unit will strengthen internal controls to prevent duplicate payments and ensure compliance with ...
Duplicate Payments to Vendors Condition Duplicate vendor payments occurred due to inadequate segregation of duties and inconsistent invoice naming conventions. Corrective Action Plan The Accounts Payable unit will strengthen internal controls to prevent duplicate payments and ensure compliance with federal cost principles. Actions include: • Enforcing segregation of duties within the AP workflow. • Implementing standardized invoice naming conventions. • Requiring secondary review for all grant-related invoices. • Conducting quarterly post-payment audits to detect and correct errors. • Implementing ERP system enhancements to flag potential duplicates. • Hiring an AP Manager to manage and improve the AP processes. Responsible Staff Chief Financial Officer (CFO) Target Completion Date June 30, 2026
CDBG Performance Reporting (ALN 14.228) Condition The PR28 and CAPER reports were submitted 11 months late. This is a repeat finding and resulted from insufficient controls and inadequate staff training. Corrective Action Plan To ensure timely and compliant reporting, the following actions will be t...
CDBG Performance Reporting (ALN 14.228) Condition The PR28 and CAPER reports were submitted 11 months late. This is a repeat finding and resulted from insufficient controls and inadequate staff training. Corrective Action Plan To ensure timely and compliant reporting, the following actions will be taken: • Developing written procedures for PR28 and CAPER preparation and submission. • Implementing a compliance calendar with required reporting deadlines. • Assigning both primary and secondary preparers to ensure redundancy. • Providing HUD IDIS training to relevant staff. • Conducting supervisory review prior to submission. • Hired a Grants Compliance Specialist to support ongoing compliance.(10/2025) Responsible Staff Grants Administrator Target Completion Date August 31, 2026
Finding 2024-001 Allowable Cost Principles and Activities Allowed or Unallowed Material Weakness in Internal Control Over Compliance Assistance Listing Number 21.029 While Wabash currently maintains informal procedures for coding and reviewing invoices and payroll records, we recognize the need for ...
Finding 2024-001 Allowable Cost Principles and Activities Allowed or Unallowed Material Weakness in Internal Control Over Compliance Assistance Listing Number 21.029 While Wabash currently maintains informal procedures for coding and reviewing invoices and payroll records, we recognize the need for a formalized, written policy governing expenditures charged to federal awards. To address identified material weaknesses, Wabash is committed to implementing a comprehensive written policy by June 30, 2026. This policy will formalize the coding, review, and reporting processes for all federal expenditures. Key improvements will include: • Enhanced Internal Controls: We will establish a clear segregation of duties to ensure oversight and accuracy. • Timely Reporting: We are refining our payroll allocation process. Previously, payroll expenditures were withheld pending budget verification, which occasionally led to reporting delays. New controls will ensure that all expenditures, including payroll, are reported within the required quarterly timeframes. • Monitoring: The Controller will oversee the development of these procedures and remain responsible for ongoing monitoring and compliance. These steps will ensure our financial practices meet federal standards and provide rigorous oversight of project funds. Contact person(s): Cheryl Gaither, Controller Justin Gephart, Chief Operating Officer
CORRECTIVE ACTION PLAN March 13, 2026 Chickahominy Indian Tribe - Eastern Division respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonbur...
CORRECTIVE ACTION PLAN March 13, 2026 Chickahominy Indian Tribe - Eastern Division respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 1909 Financial Drive Harrisonburg, VA 22801 Audit period: December 31, 2024 The findings from the December 31, 2024 Schedule of Findings and Questioned Costs (the "Schedule" ) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS- FINANCIAL STATEMENT AUDIT 2024-001: Payroll Tracking and Allocation (Material Weakness) Condition The client was unable to provide a payroll allocation by fund that agreed to the payroll registers. Criteria Payroll allocations were not supported by adequate documentation and were not consistent with methods used in the prior year. Cause The prior CFO had created an allocation method in which the existing employees could not follow . After the CFO's departure, emailed allo cat ions were sent which only specified which funding source the payroll expendit ures would be paid from, not the fund the expenditures were incurred in. Effect Material audit adjustments were required. Recommendation We recommend that payroll allocations be supported by a logical method and be allocated by fund. Corrective Action The Tribe has implemented corrective actions to strengthen internal controls over payroll allocations including: • Development and implement ation of a standardized payroll allocation model beginning with payrolls processed from September 2024 forward. • Preparation of documented allocation schedules for each pay period reconciling payroll costs to payroll registers and accounting records. • Use of standardized spreadsheet templates to support calculation and documentation of payroll allocations across funding sources . • Direct upload of payroll allocation entries into the accounting system to reduce manual entry and improve reconciliation accuracy. These procedures have established a consistent and supportable methodology for allocating payroll expenditures by fund and maintaining documentation sufficient to support financial reporting and audit requirements. The payroll allocation model was implemented beginning September 2024 and was further refined during 2025. The corrective action is considered implemented. 2024-002: Material Audit Adjustments (Material Weakness) Condition In fiscal year 2022, the Tribe elected to convert from the cash basis of accounting to governmental accrual accounting. During 2024, the Tribe continued to function on a cash basis and did not record most accruals. Criteria Financial information provided shou ld be accessible and materially correct. Cause Tribe has not consistently used the accounting software and has relied on program­ specific spreadsheets. The Tribe did not fully switch to accrual basis for internal reporting. Effect Material audit adjustments were required. Recommendation We recommend that monthly reports be generated from Abila and reviewed for accuracy. Any discrepancies between Abila reports and program-specific spreadsheets should be reconciled or adjusted. These reports should be reliable and able to be used to present to Council as part of monthly financial reporting. Corrective Action The Tribe has taken steps to strengthen the use of the accounting system as the primary source of fi nancial reporting and to improve the reliability of financial reports generated for internal management purposes including: • Continued use of the accounting system (Abila/ M IP) as the system of record for all financial t ransact ions. • Development and implementation of a revised chart of accounts structure to improve financial reporting and fund tracking. • Comprehensive review and correction of historical accounting activity to improve data integrity within the accounting system. • Use of spreadsheets as supplemental tools for monitoring estimated fund balances and grant acti vit y where necessary. • Ongoing efforts to customize financial reports generated direct ly from the accounting system so they align with the reporting format requested by Tribal leadership. The Tribe is currently working to finalize customized accounting system reports that will allow monthly financial reports to be generated directly from the accounting system in the format required for Tribal Council repo rt ing. Substantial improvements were implemented during 2025. Full implement atio n of customized accounting system reporting will be completed in the second quarter of 2026. 2024-003 : Budget Approval and Adherence (Material Weakness) Condition The budget was not approved until February 2024 and did not contain sufficient detail nor was it an accurate reflection of financial operations. Criteria Budgets should be developed with sufficient detail to track organizational performance throughout the year. Budgets should be approved by Council prior to the start of the fiscal year. Cause Unqualified staff or lack of attention to the budgeting process. Effect A budget was approved after the fiscal year and was not measured to actual performance during the year. Recommendation A thorough and detailed budget should be developed at the fund and entity level and adopted by Council prior to the start of the fiscal year. We also recommend Council meetings include a formal discussion of budget to actual results, thus giving Council an opportunity to question variances. Corrective Action The Tribe has taken steps to strengthen its budgeting process and improve financial oversight by Tribal leadership including: • Development of a detailed fiscal year 2025 operating budget at the fund and entity level to improve monitoring of financial activity across funding sources. The FY2025 budget was adopted by Tribal Council on February 8, 2025. • Development of a detailed fiscal year 2026 operating budget at the fund and entity level. This budget was presented to Tribal Council on December 19, 2025 and formally adopted with minor revisions at the January 12, 2026 Council meeting very near the start of the fiscal year. • Implementation of enhanced monthly financial reporting for Tribal leadership to support improved financial monitoring and oversight. • Ongoing development of budget-to-actual comparison reporting to support regular review of financial performance by Tribal Council. Budget development improvements were implement ed during fiscal years 2025 and 2026. Full implementation of budget-to-act ual repo rting will becompleted in the second quarter of 2026. 2024-004: Segregation of Duties (Material Weakness) Condition Certain key financial operational responsibilities are not sufficiently segregated. Criteria Proper segregation of duties shou ld be in place detect of irregulariti es in a timely manner. Cause Small staff size combined with significant turnover. Effect Segregation of duties could not be maintained in several signi fi cant rol es during the year. Recommendation Management should review the current process and implement changes to better separate responsibilities so that no one individual is responsible for a transaction cycle. Where proper segregation is not possible, mitigating controls can be put into place to detect errors. Corrective Action The Tribe recognizes the importance of segregation of duties as an internal control and has taken steps to strengthen oversight and implement mitigating controls where full segregation is not feasible due to staffing limitations including: • Increased oversight of financial transactions and accounting activit y by the Director of Finan ce. • Implementation of improved documentation and reconciliation procedures for key accounting processes. • Development of standardized processes and templates to improve consistency and transparency in financial transactions. • Implementation of enhanced financial reporting to Tribal leadership to support independent review offinancial activity. • Ongoing review of financial responsibilities and workflows to identify opportunities for improved separation of duties as staffing capacity permits. Where complete segregation of duties is not possible due to organizational size, the Tribe will continue to rely on management review and reconciliation procedures as compensating controls that have proven effective in detecting errors and irregularities. Mitigating controls were implemented during late 2024 and throughout 2025 and will continue to be refined as staffing capacity allows. 2024-005: Grant Tracking and Reporting (Material Weakness) Condition Poor financial record keeping and lack of thorough grant expenditure and status tracking. Criteria Grant funding should be recorded in separate GL accounts and be reconciled to any ext ernal spreadsheets or drawdown requests and grant reporting. Cause Turnover and unqualified staff. Effect Some grant funding sources were drawn down without documentation of qualifying expenditures, while others appear to have had qualifying expenditures that did not have matching drawdowns. Recommendation Accounting systems should be properly uti lized to track expenditures incurred under each grant and be reconciled to external reporting and spreadsheets. Once a grant is fully expended, the grant shou ld be closed out by ensuring revenues match expenditures. If expenditures are greater than the revenue provided by the grant, a transfer from the general fund would be needed. If revenues are greater than expendit ures , it could be an indication of improper drawdowns or expenditures have not been properly recorded. Corrective Action The Tribe has taken steps to strengthen grant financial management and improve reconciliation between accounting records, grant expenditures, drawdown activity, and monitoring of fund balances including: • Implementation of a revised chart of accounts structure to improve tracking of grant revenues and expenditures within the accounting system. • Continued use of the accounting system as the system of record for all financial transactions associated with grant programs. • Review and reconstruction of grant financial records to ensure expenditures, drawdow ns, and grant balances are properly documented and reconciled. • Use of standardized tracking spreadsheets as supplemental tools to monitor grant activity and reconcile grant balances to the accounting system. • Implementation of improved financial reporting and reconciliation procedures to ensure grant revenues, expenditures, drawdo wns, and balances are reviewed on a regular basis. Beginning in 2026, the Tribe has established a process to perform grant drawdowns monthly to ensure that drawdowns are aligned with recorded expenditures and that grant balances are monitored on an ongoing basis. Corrective actions began during late 2024 and continued throughout 2025. Monthly grant drawdown and reconciliation procedures were implemented in the first quarter of 2026. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAM AUDIT 2024-006: Bureau of Indian Affairs -105(1) Leases ALN 15.048 and Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments ALN 10.182, Late filing of Data Collection Form Condition The Tribe did not file the data collection form for the years ended December 31, 2022, 2023, or 2024 timely. Criteria Under the requirements of the Uniform Guidance and the Office of Management and Budget (0MB), all entities are required to file the annual data collection form with the Federal Audit Clearinghouse the earlier of 30 days after the issuance of the entity's annual audit or nine months after the entity's fiscal year-end. Management did not complete and certify the auditee portion of the form before the deadline. Questioned Cost N/A Repeat Finding Yes RecommendationManagement should take steps to ensure that the form is filed timely Corrective ActionThe Tribe has taken steps to ensure timely completion and submission of the annual data collection form going forward including: • Assignment of responsibility for preparation, review, and submi ssion of the auditee portion of the data collection form to the Director of Finance. • Establishment of a formal process to complete and certify the annual data collection form immediately upon completion of the annual audit. • Implementation of internal tracking procedures to monitor audit timelines and ensure compliance with Federal Audit Clearinghouse submission requirements. • Coordination with external auditors to ensure timely communication regarding audit completion and reporting deadlines. This corrective action has been implemented and the tribe anticipates comp liance in all future audit reporting periods beginning with FY202 5. 2024-007: Bureau of Indian Affairs -105(1) Leases ALN 15.048, Lack of Approvals (Material Weakness) Condition Criteria Cause Questioned Cost Repeat Finding Perspective Information Recommendation Corrective Action There were several instances of lack of approvals for disbursements. Federal grant recipients are required to maintain effective internal controls over federal awards, as out li ned in 2 CFR §200.303. Turnover and inadequate staffing. N/A N/A Nine of 27 tested. All disbursements should have one approval and ensure the expenditure is eligible under the grant. The Tribe has taken steps to strengthen internal controls over disbursement approvals and ensure that all expenditures are properly reviewed and documented including: • Establishment of a standardized disbursement approval process requiring documented approval prior to payment for non-routine/recurring expenditures. • Implementation of procedures to ensure all disbursements are reviewed for allowability under applicable grant requirements before payment is issued. • Maintenance of supporting documentation, including approval evidence, within the accounting records. • Ongoing review of disbursement procedures to ensure compliance with internal control requirements under 2 CFR §200.303. These measures are designed to ensure th at all disbursements are properly authorized, documented, and compliant with applicable grant requirements. Corrective actions began implementation during throughout 2025. These procedures are currently in place and will continue to be refined as part of ongoing internal control improvements. If the Federal Audit Clearinghouse has questions regarding this plan, please call Tim Emery, Director of Finance at 804-488-9392. Respectfully submitted, r Chief
Due in part to delays from the Organization’s prior auditor addressed in the Corrective Action Plan for the June 30, 2023 audit, the 2024 and 2025 audits were significantly delayed. Management has already taken steps to strengthen controls for year-end closing and audit preparation procedures to ens...
Due in part to delays from the Organization’s prior auditor addressed in the Corrective Action Plan for the June 30, 2023 audit, the 2024 and 2025 audits were significantly delayed. Management has already taken steps to strengthen controls for year-end closing and audit preparation procedures to ensure timely submission of the federal single audit reporting package. These steps included replacing the Chief Financial Officer and engaging an accounting firm to assist with the closing process. Furthermore, the Organization is working quickly to complete the 2025 audit to bring federal reporting fully up to date. Lastly, the Organization is updating its accounting procedures manual to reflect these improved practices.
The City will design and implement controls to ensure that federal awards are expended only for allowable activities.
The City will design and implement controls to ensure that federal awards are expended only for allowable activities.
Concerning Finding 2024-001-Wage Requirements Contact Person Responsible for Corrective Action: William Dobbins, Superintendent Corrective Action: The Limestone Public School will take the following actions to address finding 2024-001: The school will strengthen internal controls over federally fund...
Concerning Finding 2024-001-Wage Requirements Contact Person Responsible for Corrective Action: William Dobbins, Superintendent Corrective Action: The Limestone Public School will take the following actions to address finding 2024-001: The school will strengthen internal controls over federally funded construction projects to ensure compliance with federal wage requirements. Specifically, the School will: 1. Implement procedures to property identify construction projects charged to federal grants prior to payment approval. 2. Update procurement and contract review processes to ensure that all construction contracts exceeding $2000.00 include required federal wage rate clauses in accordance with 2 CFR Appendix II to Part 200 and 29 CFR Parts 5.2 and 5.5. 3. Require contractors performing construction work funded by federal awards to submit certified payrolls and accompanying Statements of Compliance before payments are processed. 4. Maintain documentation of certified payrolls and Statements of Compliance in accordance with federal record retention requirements. 5. Provide training to applicable administrative and finance staff on federal wage rate requirements related to construction projects funded by federal awards. Anticipated Completion Date: February 2, 2026
Finding 2024-002 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Cindy Sharp, Deputy Finance Director Corrective Action Plan: Management has hired a new finance director with governmental accounting experience, as well as an accountant (a licensed CPA in Colorado...
Finding 2024-002 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Cindy Sharp, Deputy Finance Director Corrective Action Plan: Management has hired a new finance director with governmental accounting experience, as well as an accountant (a licensed CPA in Colorado) with a long history of governmental auditing and accounting experience. Management, together with experienced accounting staff, will review reporting deadlines and work diligently toward timely report submissions in the future. Management and accounting staff will also carefully review reporting requirements and ensure that requirements are adhered to. This includes the following program(s): Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) / ARPA Non-Profit Recovery Funds (NPRF) (ALN 21.027). Proposed Completion Date: Fiscal year 2025.
Planned Corrective Action: The Division will design and implement a precise control to ensure that the inventory reports are reviewed prior to being submitted to the grantor and that the backup documentation is maintained. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon,...
Planned Corrective Action: The Division will design and implement a precise control to ensure that the inventory reports are reviewed prior to being submitted to the grantor and that the backup documentation is maintained. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller
Planned Corrective Action: The Division will design and implement a precise control to ensure that participants self-certify that they meet the grant eligibility requirements and maintain such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Divisi...
Planned Corrective Action: The Division will design and implement a precise control to ensure that participants self-certify that they meet the grant eligibility requirements and maintain such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller
Planned Corrective Action: The Division will design and implement a precise control to ensure that the amount of food distributed is properly reviewed and that the Division maintains such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Co...
Planned Corrective Action: The Division will design and implement a precise control to ensure that the amount of food distributed is properly reviewed and that the Division maintains such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller
VIDCOE will establish and document capitalization thresholds and procedures for identifying, recording, and depreciating capital assets, including maintaining a fixed asset register with periodic reconciliations. Procedures will also be implemented to ensure prepaid expenses are recorded appropriate...
VIDCOE will establish and document capitalization thresholds and procedures for identifying, recording, and depreciating capital assets, including maintaining a fixed asset register with periodic reconciliations. Procedures will also be implemented to ensure prepaid expenses are recorded appropriately and amortized over the periods benefited. In addition, grant accounting policies will be strengthened to ensure that funds received in advance are recorded as refundable advances and recognized as revenue only as allowable expenditures are incurred, in compliance with grant agreements and federal requirements. To further strengthen internal controls, VIDCOE will implement formal supervisory review and reconciliation procedures, including routine account reconciliations and financial statement reviews, to ensure transactions are properly classified, supported, and recorded. VIDCOEs’ Management expects to fully implement all corrective actions by July 30, 2026.
2024-001 Financial Reporting Material Weakness in Internal Control Material Noncompliance Condition: During our audit of the Authority’s financial statements, numerous adjustments were needed to properly report the financial statements in accordance with generally accepted accounting principles. Cer...
2024-001 Financial Reporting Material Weakness in Internal Control Material Noncompliance Condition: During our audit of the Authority’s financial statements, numerous adjustments were needed to properly report the financial statements in accordance with generally accepted accounting principles. Certain accounts had not been properly reconciled and corrective entries were not readily available. Significant audit adjustments were necessary for several audit areas and the audit was significantly delayed due to these adjustments. Auditor’s Recommendations: The Authority should continue to develop and implement internal controls over both internal and external reporting, and the year-end close process to ensure reporting remains accurate and timely, with any unexpected financial data being investigated and corrected before it is reported. The Authority should consider additional staff training on development activities. Action Taken: The Houston Housing Authority agrees with this finding and related recommendations. During this audit, as these issues arose, notes were taken, evaluation of what had happened was made so that we could make the necessary adjustments to our procedures to prevent the continuation of these issues. In addition, in the previous year we hired a firm to come in and undertake a review of the finance department. The purpose of this review was to review our existing staffing levels, workloads, experience, etc., for purposes of proposing a reorganization of the finance department to address any deficiencies. We have reviewed the recommendations from this consultant and are in the process of implementing many of the recommended changes. There have been a number of staffing changes made during the year with the intent of improving the overall performance of the finance department. We are in the process of evaluating if additional staff are needed to expand the capacity of the Finance department. In November of 2024 the Houston Housing authority converted to a new accounting system. The Yardi system was implemented and we began processing all transactions on this new system. Unfortunately, there have been a significant amount of post implementation corrections and modifications that have had to be made and continue to occur. We are still undergoing these implementation and modification processes and as a result of this we continue to have to make adjusting entries to correct errors as they are discovered. To further complicate this system conversion there were a number of changes made to the management companies that we utilize to do our primary property level accounting. They have also been converting portions of their accounting systems to Yardi. Many of the same problems that have been encountered during our system conversion have also been encountered by the management companies. It is anticipated that most of these system conversion related issues will be resolved within the 2025 calendar year. The VP Fiscal and Business Operations as well as the Director of Finance are responsible for implementing the necessary process and procedural changes to eliminate the need for this type of finding for the 2024 audit.
Eligibility Housing Voucher Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 1,500 of Housing Voucher Cluster tenants we tested 11 tenants and the following deficiencies were noted: Five files did not have an annual recertification p...
Eligibility Housing Voucher Cluster Material Weakness in Internal Control Material Noncompliance Condition: Out of an approximate population of 1,500 of Housing Voucher Cluster tenants we tested 11 tenants and the following deficiencies were noted: Five files did not have an annual recertification performed with 12 months of the previous certification Two files did not have inspection documentation during the period, One file did not have an annual recertification performed, One file did not have documentation to support HAP amount reported, One file used an incorrect payment standard, One file did not have dependency documentation for a dependent member of the household, One file was missing documentation to support income claimed during recertification, and One file will missing rent reasonableness documentation and approval. Auditor Recommendations: The Authority should reevaluate their established procedures and controls in place to ensure full compliance in regards to eligibility and the timeliness of recertifications. The Authority needs to correct the deficiencies noted in the tested files and consider the impact to the rest of the population of tenant files that were not selected as part of the auditor’s sample. Action Taken: The Houston Housing Authority agrees with this fining and related recommendations. During 2024 the voucher and public housing programs converted to a new software system. Yardi is not the principal operating system for both the voucher and public housing programs. This system conversion has required that work flows had to be modified. This modification and implementation of a new processing system did not allow staff to conduct the necessary reviews of existing files to make sure that the compliance related materials that should be found in each file were to be completed. This issue has been discussed and there will be an internal review conducted on file samples to determine what compliance deficiencies are prevalent. Corrective action steps will be implemented to address these issues designed to correct them. Additional training resources will be devoted to staff in these departments designed to improve quality control with these program areas.
93.796 State Survey Certification of Health Care Providers and Supplies (Title XIX) Medicaid 2024-022 Strengthen Controls to Ensure Compliance with Provider Health and Safety Standards Requirements of the Medical Assistance Program DOM Response: One hundred of 196 nursing facilities did not have man...
93.796 State Survey Certification of Health Care Providers and Supplies (Title XIX) Medicaid 2024-022 Strengthen Controls to Ensure Compliance with Provider Health and Safety Standards Requirements of the Medical Assistance Program DOM Response: One hundred of 196 nursing facilities did not have mandatory health and safety survey within required 15.9 month survey interval. Statewide average survey interval for nursing home facilities was 20.37 months, exceeding required 12-moth average between surveys. DOM Concurs. During the period of the government shutdown, standard Medicare-funded recertification surveys were not performed. This included statutorily mandated surveys (Nursing facilities, Home health agencies, etc.) which contributed to delays in survey completion timelines. Since the June 2024 audit findings, the Mississippi State Department of Health (MSDH) has made significant improvements in completing required surveys. According to the Annual Survey Report submitted in January 2026, the average time to complete surveys decreased to 16.9 months, improving from the previous average of 20.37 months. While this timeframe still exceeds the required 12-month average interval between surveys, it represents meaningful progress toward compliance. Additionally, the Division of Medicaid (DOM) and MSDH are collaborating with the Centers for Medicare & Medicaid Services (CMS) to participate in the Nurse Staffing Campaign. This initiative is designed to increase the number of nurses in nursing homes to improve resident health and safety. A portion of the funding will also support the hiring of additional surveyors within MSDH, which will help the agency move toward full compliance with mandatory health and safety survey requirements and meet the required 15.9-month survey interval. DOM Corrective Action Plan: a. The Division of Medicaid (DOM) and MSDH are collaborating with the Centers for Medicare & Medicaid Services (CMS) to participate in the Nurse Staffing Campaign. This initiative is designed to increase the number of nurses in nursing homes to improve resident health and safety. A portion of the funding will also support the hiring of additional surveyors within MSDH, which will help the agency move toward full compliance with mandatory health and safety survey requirements and meet the required 15.9-month survey interval. b. Misty Jenkins c. March 31, 2027
93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) 2024-023 Strengthen Controls to Ensure Compliance with Provider Eligibility Requirements of CHIP and the Medical Assistance Program DOM Response: Two instances of no documentation that required ...
93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) 2024-023 Strengthen Controls to Ensure Compliance with Provider Eligibility Requirements of CHIP and the Medical Assistance Program DOM Response: Two instances of no documentation that required fee were collected. DOM Partially Concurs. After a review of the 2 files, DOM has found in one instance an application fee was collected and sent to DOM for processing; however, the receipt of the application fee was not indicated by comments in the system. DOM will work with Gainwell to ensure remedial training is conducted to reduce errors in the future. One (1) instance correlates to an application received before DOM began requiring the fee on October I, 2022. Thirty-eight instances of no documentation that provider's medical license was current and free of limitations. DOM Partially Concurs. After a review of the 38 files, DOM has found in thirty-one (31) instances the license from the board was attached and the checklist completed after the license was not verified by LexisNexis . Two (2) instances were applications approved prior to the Gainwell implementation; however, the licenses remain valid in SFY 2024 and reflect correct effective dates in the system. One (1) instance is a group and does not require license. Four (4) instances the license from the board was manually verified and attached after the license was not verified by LexisNexis; however, there were typographical errors or omissions in the license fields in the system. DOM will ensure Gainwell conducts remedial training to mitigate these errors in the future. Thirty-one instances of no documentation of review prior to approval of provider's application. DOM Does Not Concur. After a review of the 31 files, DOM has verified all applications identified within this finding as being approved by DOM without review have documented comments in the system of record to show a review of each application was conducted prior to approval. This would include Fifteen (15) instances with review notes, requests for missing information (if applicable), etc. entered by reviewers since the Gainwell Go-Live. Sixteen (16) instances with review notes, requests for missing information (if applicable), etc. entered by reviewers prior to the Gainwell Go-Live. Ten instances of no documentation of verified identity and exclusion status of providers using required federal databases prior to application approval. DOM Partially Concurs. After a review of the 10 files, DOM has found in five (5) instances the LexisNexis report indicated the NPI was verified. One (I) instance of the NPI not verified by LexisNexis, but the Gainwell Analyst performed a manual search in NPPES and attached the verification results on 11/14/24. Four (4) instances before Gainwell began processing applications. The provider was sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Agency began revalidation in 2017 by stratifying all providers; however, due to PHE all revalidations were paused. As a result, not all revalidations have been completed. At this time, revalidation dates have been assigned in alignment with CMS guidance and will be completed within CMS required timelines, i.e. 44 months from end of the PHE. One (I) instance has a note indicating revalidation occurred in 2017, but no documentation can be located in the system, which potentially could be attributed to data conversion from the legacy system to the new system. Four instances of no documentation of OIG exclusion checks prior to application approval. DOM Concurs. After a review of the 4 files, DOM has found in three (3) instances contain a comment within EDMS that verifies the providers were sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Please note: Agency began revalidation in 2017 by stratifying all providers, however due to PHE all revalidations were paused. As a result, not all revalidations have been completed. At this time, revalidation dates have been assigned in alignment with CMS guidance and will be completed within CMS required timelines, i.e., 44 months from end of the PHE. One (1) instance has a note indicating revalidation occurred in 2017, but no documentation can be located in the system, which potentially could be attributed to data conversion from the legacy system to the new system. Two instances of no documentation of collection of the provider's NPI. DOM Concurs. After a review of the 2 files, DOM has found all instances contain a comment within the system which verifies the provider was sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Eight instances of missing or incomplete documentation of required disclosure details. DOM Partially Concurs. After a review of the 8 files, DOM has found in two (2) instances where the individual provider's date of birth is in the system. Two (2) instances where the individual provider's date of birth is not available as it was not a required element at the time of application. DOM will ensure the date of birth is obtained from the provider and added to the system. Three (3) instances where the organizational provider has all required elements. One (1) instance where the organizational provider's address is not available as it was not a required element at the time of application. The missing data is now required and will be collected at the next revalidation. Four instances of no documentation required screening procedures in accordance with provider's designated risk level. DOM Partially Concurs. After a review of the 4 files, DOM has found in three (3) instances where the individual provider's file contains a comment within EDMS verifies provider was sent to Digital Harbor for screening. DOM's contractual relationship with Digital Harbor ended in 2016 and the data is no longer available. Please note: Agency began revalidation in 2017 by stratifying all providers, however due to PHE all revalidations were paused. As a result, not all revalidations have been completed. At this time, revalidation dates have been assigned in alignment with CMS guidance and will be completed within CMS required timelines, i.e., 44 months from end of the PHE. One ( l) instance the individual provider was screened, and a site visit was conducted (as this provider type was deemed moderate risk at that time) and the documentation is available in the system. DOM Corrective Action Plan: a. In response to the audit findings, the Division of Medicaid (DOM) will collaborate with its Fiscal Agent, Gainwell Technologies, to review all identified issues and implement corrective measures. As part of this effort, mandatory refresher and remedial training will be conducted for Gainwell Provider Enrollment staff. This training will emphasize the requirement for comprehensive and accurate documentation within provider files, including clear, detailed, and supportive comments that fully reflect all actions taken during the enrollment and maintenance processes. Additionally, DOM will implement enhanced oversight and quality assurance monitoring to ensure sustained compliance with documentation standards. DOM notes that certain discrepancies identified in the audit may predate the implementation of the MESA system and the transition to Gainwell Technologies as the Fiscal Agent. Due to system conversion constraints, data limitations, and the absence of complete historical documentation within the current system, DOM's ability to retrospectively validate or remediate these pre-implementation discrepancies is limited. As such, corrective actions will be applied prospectively, with a focus on ensuring accuracy, completeness, and compliance within the current MESA environment moving forward. b. Bill Hardin c. March 31, 2026
93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2024-021 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: Use...
93.767 Children's Health Insurance Program (CHIP) 93.778 Medical Assistance Program (Medicaid; Title XIX) Eligibility 2024-021 Strengthen Controls to Ensure Compliance with Eligibility Requirements of the Children's Health Insurance Program (CHIP) and the Medical Assistance Program DOM Response: Use of Tax Return Resources Three MAGI beneficiaries - DOM did not verify self-employment income reported on tax return One of the 180 MAGI beneficiaries - reported self-employment income, DOM did not request a tax return DOM Does Not Concur. OSA compared eligibility data to state income tax returns. DOM is prohibited from accessing state income tax records per Mississippi Code Annotated 27-3-73 and currently, is not allowed to have access to federal income tax records. For eligibility, DOM asserts compliance with the CMS-approved state plan. During the audit period, the state used the CMS MAGI Based Verification plan to confirm income reports using all available electronic data sources according to CMS's reasonable compatibility standard. DOM must accept applicant information and use CMS-approved verification methods to check its accuracy. If self-employment income is not reported and DOM's tools do not detect it, DOM has met eligibility and compliance standards set by CMS. In addition, tax returns are considered outdated and not relevant to DOM. Six of the 180 MAGI beneficiaries - income was not verified through Mississippi Department of Employment Security DOM Partially Concurs. Four beneficiaries' income was not verified through Mississippi Department of Employment Security (MDES). DOM requested MDES on the identified beneficiaries and found no new information that would have affected the eligibility decision. DOM does not concur with two of the findings as MDES was requested on those beneficiaries. Each finding will be reviewed with the individual team members and additional communication has been provided to all Eligibility Team Members. Twelve of the 300 beneficiaries - the beneficiary's case file did not contain a completed application. DOM Concurs. DOM was unable to locate and provide the auditors the original application for the twelve beneficiaries. These documents do not impact the redetermination of eligibility. All redetermination decisions have been verified as accurate. Six of the 300 beneficiaries - DOM could not provide a case file. DOM Concurs. DOM was unable to locate and provide the auditors the case files for six beneficiaries. These documents do not impact the redetermination of eligibility. All redetermination decisions have been verified as accurate. One ABD beneficiary - resources were not verified through AVS at the time of redetermination. DOM Concurs. DOM has since requested AVS records for the beneficiary in question. No bank accounts were found, which indicates there was no impact to eligibility. The Eligibility Team Member will be coached to ensure appropriate processes are followed for all future cases. One hundred thirty-five beneficiaries were not included on all of the required quarterly Public Assistance Reporting Information System (PARIS) file transmissions for fiscal year 2024. DOM Partially Concurs. DOM does not concur with a number of these findings as they were appropriately absent from the PARIS request file because they were in a denied status, had retroactive coverage, or was absent due to the timing of the case approval. DOM concurs with some of the findings. Findings related to COE 29 - Family Planning were addressed in late 2023, which was after the approval of these cases. This issue was resolved in late 2023. There were findings that occurred due to the timing of the PARIS file. DOM has submitted a change request to submit the PARIS file based on the run date not based on the end of the previous month. All previously missed members were added to the 11/1/2025 PARIS outgoing data file, and this report was provided to the auditors. No eligibility decisions were affected by the 11/1/2025 returned PARIS file. DOM Corrective Action Plan: a. DOM submitted a change request to submit the PARIS file based on the eligibility end date of the previous quarter rather than the actual run date. This has been completed. All individual issues identified will be reviewed with the appropriate team member. b. Brian Whitmire c. March 31, 2026
ALN Number 2024 -037 93.558 Temporary Assistance for Needy Families (TANF) 93.568 Low-Income Home Energy Assistance Program (LIHEAP) Strengthen Controls to Ensure Compliance with Federal Funding Accountability and Transparency Act (FFATA) Reporting Requirements. Federal Award No. All Current Active ...
ALN Number 2024 -037 93.558 Temporary Assistance for Needy Families (TANF) 93.568 Low-Income Home Energy Assistance Program (LIHEAP) Strengthen Controls to Ensure Compliance with Federal Funding Accountability and Transparency Act (FFATA) Reporting Requirements. Federal Award No. All Current Active Grants Response: MOHS does not concur with this finding. MOHS has implemented and adhered to standardized operating procedures (SOPs) over the past year to ensure timely and periodic reporting under the Federal Funding Accountability and Transparency Act (FFATA). In March 2025. the federal government retired the Federal Subaward Reporting System (FSRS), which MDHS used to submit new and modified awards. The successor platform, SAM.gov. launched with migrated award data that reflects only the most recent award amount. Historical submission details-including the timestamps that demonstrated timely filings-were not retained in the migrated records. Because the majority of MDHS's FFATA submissions typically occur in November and January. the migrated data does not display the original submission dates associated with those reports. Following the retirement of FSRS, MDHS no longer has access to the legacy system and therefore cannot produce the historical report previously used to verify timely submission. Additionally, the compliance supplement does not address the FFATA reporting processes within SAM.gov. Notwithstanding these system changes, MOHS continues to prepare and submit FFATA reports in accordance with its established SOPs and within the required timeframes. Corrective Action Plan: MOHS will make efforts to create practical. auditable processes to ensure timely and accurate FFATA reporting and solid proof of timeliness and completeness, in the new system.
ELIGIBILTY ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 202 -035 Strengthen Controls to Ensure Compliance With Eligibility Requirements of the Temporary Assistance for Needy Families (TANF) Program . Federal Award No. All Current Active Grants Response: MDHS has implemented a mul...
ELIGIBILTY ALN Number 93.558 Temporary Assistance for Needy Families (TANF) 202 -035 Strengthen Controls to Ensure Compliance With Eligibility Requirements of the Temporary Assistance for Needy Families (TANF) Program . Federal Award No. All Current Active Grants Response: MDHS has implemented a multi-tiered approach to address the audit findings from the Fiscal Year 2024 Single Audit. These efforts focus on strengthening eligibility controls and enhancing internal oversight. MDHS is required to adhere to specific eligibility and verification standards for the TANF program. including mandatory immunization checks, age limit monitoring. and proper authorization of work stipends. During the Fiscal Year 2024 Single Audit 16 instances were identified where these controls were not fully met. resulting in questioned costs of $2,592. MDHS has already taken steps to address the identified overpayments and documentation gaps. To correct these deficiencies, MDHS is strengthening its internal control processes within the Division of Economic Assistance and Eligibility (DEAE) to ensure that immunization records are verified within the required thirty (30) day window· and benefit adjustments for children reaching age eighteen (18) are processed promptly. Furthermore. MDHS is implementing case reviews to ensure all payments are approved by authorized personnel and that work stipends are supported by completed applications and accurate attendance records. MDHS has committed to ongoing staff training to prevent the recurrence of these eligibility and authorization errors. Corrective Action Plan: I. Child's current immunization status was not verified within thirty (30) days. A. DEAE provides policy guidelines via a weekly "Did You Know" email to all staff. Information regarding the immunization requirement will be included in this series by June I. 2026. Statewide TANF and TWP training will begin on June 1. 2026 B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs, Marilyn Williams, Deputy Division Director- Field Operations. Marshea Cooper, Deputy Division Director- State Operations C. Anticipated Completion Date: August I. 2026 2. TANF benefits were not reduced promptly once a dependent child reached 18 years old. resulting in overpayment. A. There is a report generated monthly that identifies children in households that will reach their 18th birthday one month prior to their 18th birthday. In addition, DEAE conducted training in February and March 2026 with regional directors. county directors. and supervisors that included information on using the above-mentioned report to prevent overpayment due to dependent children turning 18 B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs. Marilyn Williams. Deputy Division Director- Field Operations. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: This corrective action has been implemented and completed. 3. TANF benefit payment \Vas approved by an unknown authorizer. A. This finding is due to a system issue that has been resolved. MIS identified that the system did not hold the names of employees who left the agency and replaced the name with “unknown authorizer” Cases now hold the authorizer’s name going forward from the fix. B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs. Marilyn Williams. Deputy Division Director- Field Operations. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: This corrective action has been implemented and completed. 4. Transportation work stipend was overpaid based on the recipient's scheduled hours. A. DWD revie\vs cases monthly to identify errors. Statewide TANF and TWP training will begin on June 1. 2026 . B. Responsible Parties: Shauna Aguilar, Deputy Director- Economic Programs. Marilyn Williams. Deputy Division Director- Field Operations. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: In progress and ongoing 5. Transitional work stipends were paid to recipients without completed applications on file. A. Statewide TANF and TWP training will begin on June 1·. 2026 . B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs. Marilyn Williams. Deputy Division Director- Field Operat ions. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: August I. 2026 6. Transitional work stipend amounts paid to recipients were incorrect based on attendance records. A. The TANF Policy team will begin reviewing transition cases on May I. 2026. B. Responsible Parties: Shauna Aguilar. Deputy Director- Economic Programs. Marilyn Williams, Deputy Division Director- Field Operations. Marshea Cooper. Deputy Division Director- State Operations C. Anticipated Completion Date: Implementation May I. 2026 and ongoing process
Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-016 1. Finding Summary The auditor determined that Pell Grant funds were disbursed for summer enrollment without adequate documentation demonstrating that students met all required summer Pe...
Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-016 1. Finding Summary The auditor determined that Pell Grant funds were disbursed for summer enrollment without adequate documentation demonstrating that students met all required summer Pell eligibility criteria. As a result, the institution could not demonstrate compliance with federal requirements governing the award and disbursement of additional Pell Grant funds for summer terms. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Pell Grant funds were disbursed for summer enrollment without consistently ensuring and documenting that all federal summer eligibility requirements were met prior to disbursement. 3. Root Cause Analysis The root cause of this finding resulted from insufficient supervisory review of summer Pell eligibility determinations and gaps in staff training regarding federal requirements for awarding and disbursing additional Pell Grant funds for summer enrollment. 4. Corrective Action(s) Management has added secondary review, implemented periodic internal monitoring, and conducted targeted staff training tied to updated procedures. Description of Corrective Actions The institution has added a required supervisory or secondary review to confirm summer Pell eligibility prior to processing or disbursement, implemented periodic internal monitoring and quality assurance reviews to verify ongoing compliance, and conducted targeted staff training aligned with updated summer Pell eligibility procedures. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of improperly awarding or disbursing Pell Grant funds for summer enrollment by strengthening supervisory oversight, improving staff understanding of summer eligibility requirements, and ensuring eligibility is reviewed and verified prior to disbursement. Ongoing monitoring and quality assurance reviews provide additional safeguards to identify and prevent future noncompliance. 6. Responsible Party • Office/Department: Office of Financial Aid • Title of Responsible Official: Director of Financial Aid • Name (optional): 7. Implementation Timeline • Corrective action implemented: Yes (No) • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) Fully implemented Partially implemented (Not yet implemented) Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability Ongoing supervisory review and periodic internal monitoring will be conducted to ensure summer Pell eligibility requirements are consistently met and documented prior to disbursement. Continued staff training, standardized review procedures, and quality assurance checks will be maintained to support long-term compliance and timely identification and correction of any eligibility issues.
Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-012 1. Finding Summary The auditor determined that the institution disbursed Pell Grant funds more than 10 days prior to the first day of classes, in vio]ation of federal Title IV disburseme...
Federal Program/ Assistance Listing Number (ALN) 84.268, 84.063, 84.007, 84.033 Finding Reference Number 2024-012 1. Finding Summary The auditor determined that the institution disbursed Pell Grant funds more than 10 days prior to the first day of classes, in vio]ation of federal Title IV disbursement timing requirements. As a result, the institution could not demonstrate compliance with applicable federal regulations governing the timing of Pell Grant disbursements. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that Pell Grant funds were disbursed earlier than permitted under federal Title IV disbursement timing requirements due to a miscalculation of the days. 3. Root Cause Analysis The root cause of this finding resulted from by inaccurate or prematurely scheduled disbursement dates, limited coordination between the Financial Aid and Business Offices on the approved disbursement calendar, and insufficient controls to ensure Pell Grant funds were released in accordance with federal timing requirements. 4. Corrective Action(s) Management will implement a standardized calendar of disbursement dates annually based on the academic calendar. Description of Corrective Actions Management will prepare an annual disbursement calendar based on the academic calendar, which will be reviewed by both the Business Office and Office of Financial Aid to ensure compliance to federal Title IV disbursement timing requirements. 5. Risk Mitigation (Required - Even if Disagreeing) These corrective actions reduce the risk of early federal disbursements by strengthening oversight, implementing a disbursement calendar, and reinforcing staff understanding of federal timing requirements. 6. Responsible Party • Office/Department: Business Office • Title of Responsible Official: Senior Accountant • Name (optional): ___ _________ _ 7. Implementation Timeline • Corrective action implemented: (Yes) No • If not fully implemented, expected completion date: June 30, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) (Fully implemented) Partially implemented Not yet implemented Evidence of Implementation Academic Year 2026-2027 Disbursement Calendar. 9. Monitoring and Sustainability The University will continue to prepare a disbursement calendar annually before any new year disbursements are made.
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