Corrective Action Plans

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Corrective Action Plan Thursday, February 12, 2026 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the June 30, 2025 audit report dated February 13, 2026 schedule of findings and questioned cost are discu...
Corrective Action Plan Thursday, February 12, 2026 Harrisburg Area Community College respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the June 30, 2025 audit report dated February 13, 2026 schedule of findings and questioned cost are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Agency: (Federal Agency per Finding): U.S. Department of Education Audit Period: July 1, 2024 – June 30, 2025 Name and Address of independent public accounting firm: Smith Elliott Kearns & Company, LLC, Certified Public Accountants & Consultants, 804 Wayne Avenue, Chambersburg, Pennsylvania 17201 Finding Type: (per Finding) Federal Awards: Material Weakness in Internal Control over Compliance and Noncompliance Internal Control Type: (please choose the type per the finding)  Material Weakness(es) o Significant Deficiencies Audit Finding No.: 2025-001 Federal Program: (per Finding) Student Financial Assistance Cluster Compliance Requirement: (per Finding) Return of Title IV Funds Audit Finding Title/Statement of Condition: (copy from audit findings documentation): The College did not comply with federal requirements related to the timely return of Title IV funds. Specifically, the College failed to return aid for four students who never attended within the 30-day period required under 34 CFR 668.21(b). In addition, the College did not return funds for one student who began attendance but subsequently required a refund within the 45-day timeframe mandated under 34 CFR 668.173(b). Auditor Recommendation: (copy from audit findings documentation) The College should strengthen its internal controls and monitoring procedures to ensure compliance with federal return-of-funds requirements. This should include timely verification that calculated refund amounts match what is actually returned, improved review processes to confirm that students who never attended are identified promptly, and training for relevant staff to ensure consistent understanding and execution of federal aid return requirements. Specific steps to be taken to correct the situation [including a timetable for performance of the CAP] or reason why corrective action is not necessary (including disagreement with the finding). The College has made several enhancements that should prevent future problems with the return of funds. 1) In fall 2025, the College instituted a new process for collecting data for attendance/participation of students. This process includes a data collection approximately one week into the part of term (the “Academic Participation Data Collection) – and before the disbursement of Title IV aid. It also includes follow up with faculty at several intervals throughout the semester to encourage them to withdraw students who have stopped attending. This improved process gives us clearer and more transparent data on attendance/participation so that aid recalculations and returns can be managed in a more timely manner 2) As of January 2025, the College has implemented a process to prevent the disbursement of Title IV (TIV) aid to students who are not enrolled in a future semester or are not considered actively attending. For example, if a student attended the Fall semester but is not enrolled for the Spring semester, Title IV funds cannot be disbursed if the aid was not originated before the student became ineligible. This process applies in both directions, as disbursement includes both paying funds to a student’s account and reversing funds when appropriate. Accordingly, the Previous Semester Fund Request process is designed to ensure that Title IV funds are either paid or reversed in compliance with federal requirements. 3) The Financial Aid team will continue processing returns at the time that an R2T4 occurs to prevent miscommunications and ensure timely completion. 4) The Financial Aid team and Finance teams will collaborate and engage Bank Mobile to improve the processing of stale checks and timed out funds. Anticipated Completion Date: May 1, 2026 Name(s) and Title(s) of contact person(s) responsible for correction action: Tim Barshinger, Associate Vice-president of Student Enrollment Services Juan Cordoba, Financial Aid Director
FINDING 2025-004 Subject: COVID -19 - Education Stabilization Fund - Cash Management Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the find...
FINDING 2025-004 Subject: COVID -19 - Education Stabilization Fund - Cash Management Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation will implement and consistently apply a standardized two-level review and approval process for all grant reimbursements to ensure proper accounting, documentation, and compliance. The grants administrator (or designee) will prepare and conduct the initial review of each grant reimbursement to verify that all expenses and receipts contain the correct accounting information, are properly documented, and are recorded in the appropriate accounts within the Financial Management System (FMS). The Corporation Treasurer (or designee) will perform an independent secondary review of all grant reimbursements, including a review of supporting documentation and account coding, and will provide final approval and signature as evidence of authorization. On a monthly basis, grant accounts will be reviewed by the grants administrator for accuracy and completeness, with the Corporation Treasurer (or designee) conducting a secondary monthly review to confirm accuracy and compliance. This two-level review process ensures adequate segregation of duties, strengthens internal controls, and provides documented oversight of all grant reimbursement activity. Anticipated Completion Date: The ESSER grant is finished. If we were to receive this grant in the future, Silver Creek School Corporation would apply the procedures in the corrective action plan.
FINDING 2025-003 Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views...
FINDING 2025-003 Subject: COVID -19 - Education Stabilization Fund – Activities Allowed and Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Allison Vanover, Corporation Treasurer. Contact Phone Number 812-246-3375 Email Address: avanover@scsc.school Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Corporation will implement and consistently apply a standardized two-level review and approval process for all grant reimbursements to ensure proper accounting, documentation, and compliance. The grants administrator (or designee) will prepare and conduct the initial review of each grant reimbursement to verify that all expenses and receipts contain the correct accounting information, are properly documented, and are recorded in the appropriate accounts within the Financial Management System (FMS). The Corporation Treasurer (or designee) will perform an independent secondary review of all grant reimbursements, including a review of supporting documentation and account coding, and will provide final approval and signature as evidence of authorization. On a monthly basis, grant accounts will be reviewed by the grants administrator for accuracy and completeness, with the Corporation Treasurer (or designee) conducting a secondary monthly review to confirm accuracy and compliance. This two-level review process ensures adequate segregation of duties, strengthens internal controls, and provides documented oversight of all grant reimbursement activity. Anticipated Completion Date: The ESSER grant is finished. If we were to receive this grant in the future, Silver Creek School Corporation would apply the procedures in the corrective action plan.
FINDING 2025-003 – Reporting Material Weakness in Internal Control over Compliance and Instance of Material Noncompliance Views of responsible officials and planned corrective actions: Management agrees with the assessment. To address this issue, management has reinforced and formalized its reportin...
FINDING 2025-003 – Reporting Material Weakness in Internal Control over Compliance and Instance of Material Noncompliance Views of responsible officials and planned corrective actions: Management agrees with the assessment. To address this issue, management has reinforced and formalized its reporting reconciliation controls. All financial and performance reports submitted for WIOA programs will be reconciled to supporting documentation prior to submission. Management has clarified roles and responsibilities to ensure that report preparation and review are performed by separate individuals. All reports required by contract must be submitted timely and must include two levels of documented review. Reports will be reviewed by the preparer’s Director (or their designee); if the Director is the preparer, the review will be conducted by the Chief Operating Officer or in their absence, the Chief Executive Officer. All financial reports required by contract must have documented review by a member of the fiscal department. Supporting documentation related to report reconciliations will be retained to ensure traceability and availability for review. During the year, the department experienced a leadership transition, and the new Director is receiving additional training on reporting requirements and internal control expectations. Management will also provide periodic training to staff involved in report preparation and review to reinforce control requirements and expectations. Management expects significant improvement for the fiscal year ending in 2026. Contact Persons: Ryan Berendsen, Chief Operating Officer Delana Kromer, Controller
Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the sub...
Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the subrecipient's behalf. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective October 1, 2025, all subrecipients were notified that payments would be made only to them, requiring them to directly pay their contractors and vendors. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: October 1, 2025
Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring the review and approval of performance, with such review and approval clearly documented. Ex...
Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring the review and approval of performance, with such review and approval clearly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective January 1, 2026, the Executive Director will review a PDF copy and document approval via email of OARN's Semi-Annual Progress Reports prior to uploading into the EHB. Name(s) of the contact person(s) responsible for corrective action: Kendra Jones, Executive Director Planned completion date for corrective action plan: January 1, 2026
Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement policies and procedures to ensure the performance of subrecipient monitoring and that the monitoring is formally documented and appro...
Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement policies and procedures to ensure the performance of subrecipient monitoring and that the monitoring is formally documented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OARN's current monitoring of Subrecipients has included reviewing budgets and progress reports, approving vendors, and processing drawdown requests to confirm the appropriate use of subaward funds in compliance with Federal regulations and subaward terms. However, OARN recognizes the need for a more comprehensive review process to ensure full subrecipient compliance. Therefore, we plan to request audits or financial reviews from all subrecipients. We will also require documentation demonstrating that the subrecipient has taken prompt and necessary corrective action in response to any deficiencies identified through audits, on-site reviews, or other methods related to the Federal program. OARN has created and will maintain a Subrecipient Monitoring and Approval Form that tracks receipt and review of 1) audit reports and corrective actions along with 2) checks on SAM.gov to confirm the subrecipient's continued eligibility for federal funds. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: March 30, 2026
2024-014 SPECIAL TESTS AND PROVISIONS - HEALTH AND SAFETY REQUIREMENTS DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.575/93.596 The Quality Assurance specialists have established a plan of action for each Regulation Unit (Child Care Licensing Unit and Family Child Care Unit) to m...
2024-014 SPECIAL TESTS AND PROVISIONS - HEALTH AND SAFETY REQUIREMENTS DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.575/93.596 The Quality Assurance specialists have established a plan of action for each Regulation Unit (Child Care Licensing Unit and Family Child Care Unit) to maintain continual monitoring of conducted Annual Unannounced Monitoring Visits required under 45 CFR §98.42(b)(2)(i)(B). Within the tracking spreadsheet, detailed information is input from our documentation system PATH COGNOS Report PCC-PLI 1080. Information includes Provider Name, Provider Number, Provider Type, Specialist Name, and columns for visits conducted and visits not yet conducted. To provide an overall year-to-date calculation of monthly totals/percentages, a Yearly Summary tab is included in the spreadsheet for a quick reference analysis to provide an additional method of tracking visits. As the monthly totals and percentages change, the data updates on the monthly tabs and the Yearly Summary tab. Program Managers have implemented individual efforts to track visits conducted by specialists. The PCC-PLI 1080 report is distributed twice per month by PM II to each Program Manager for review. Specialists have been instructed to include completed annual unannounced monitoring visits on monthly report data, which can then be compared with the PCC-PLI-1080 reports. Additionally, a tracking system has been implemented that requires specialists to pre-plan annual unannounced visits for the 2026 calendar year to ensure visits are completed.
2025-022 SPECIAL TESTS AND PROVISIONS – INCOME ELIGIBILITY AND VERIFICATION SYSTEM DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.558 Effective April 1, 2026, the Department of Human Services’ Bureau for Family Assistance will implement a series of mandatory training and policy en...
2025-022 SPECIAL TESTS AND PROVISIONS – INCOME ELIGIBILITY AND VERIFICATION SYSTEM DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.558 Effective April 1, 2026, the Department of Human Services’ Bureau for Family Assistance will implement a series of mandatory training and policy enhancements designed to bolster compliance and documentation standards for all WV WORKS workers. The primary focus of these updates is the rigorous handling of data matches; specifically, workers must complete a Blackboard course on Single Agency Audits that emphasizes the necessity of documenting all Income and Eligibility Verification System (IEVS) matches. To support this at the foundational level, an IEVS case comments exercise has been integrated into the third week of the standard training curriculum. Monitoring and quality control will also enhance Rushmore Review protocols. Supervisors are now required to perform three Rushmore Reviews per month, while the WV WORKS policy team will continue their own reviews to track systemic trends. Furthermore, the Division of Performance and Quality Improvement (DPQI) will now include specific compliance checks for data match completion within their monthly review of 18 cases. To ensure staff are well-equipped for these changes, the Division of Professional Development has released a suite of resources, including procedural Desk Guides and supplementary YouTube training videos. Supervisors are required to present them during monthly unit meetings. To finalize the process, every worker must provide a formal sign-off to confirm they have received and understood the updated procedures regarding data exchanges. 85
2025-007 SPECIAL TESTS AND PROVISIONS: UI BENEFIT PAYMENT WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 WFWV acknowledges and agrees with the finding that Benefit Accuracy Measurement (BAM) cases were not reviewed and closed within the time limits established by ET Handbook No. 39...
2025-007 SPECIAL TESTS AND PROVISIONS: UI BENEFIT PAYMENT WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 WFWV acknowledges and agrees with the finding that Benefit Accuracy Measurement (BAM) cases were not reviewed and closed within the time limits established by ET Handbook No. 395. During the performance year, the BAM team faced significant staffing challenges, which delayed the timely completion of audits and restricted the availability of personnel for reviewing completed cases. To address this issue, WFWV has implemented the following corrective measures: 1. Trained a support staff member in November 2024 to assist BAM analysts with administrative tasks, including setting up new case files, issuing second and third requests for information, and calculating wages based on employer-provided verification forms. This support enables analysts to dedicate more time to core investigative work. 2. Hired an additional BAM analyst in November 2025 to reduce management’s workload in completing audits, allowing them to prioritize the review of completed cases. Furthermore, as of January 2026, management and the BAM support staff now use a shared redesigned spreadsheet to track the progress of assigned cases. This tool provides real-time visibility into case statuses, ensuring more effective monitoring of completion timeliness and preventing future delays.
2025-005 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF EDUCATION (DOE) Assistance Listing Numbers: 10.553/10.555/10.556/10.559/10.582 During FY 2025, the FFATA reporting system changed from the FSRS site to SAM.gov. Many transactions that were originally enter...
2025-005 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF EDUCATION (DOE) Assistance Listing Numbers: 10.553/10.555/10.556/10.559/10.582 During FY 2025, the FFATA reporting system changed from the FSRS site to SAM.gov. Many transactions that were originally entered into the FSRS site did not transfer over and had to be re-entered into SAM.gov, making those entries appear late. In addition, we had trouble getting the SAM.gov site to accept our FFATA entries. DOE worked with SAM.gov customer support to eventually get the issues resolved, but this also resulted in late reporting. Subsequent to the systematic issues being resolved, all FFATA reports have been completed timely and will continue to be reported timely going forward.
Condition: The Organization lacked adequate controls to ensure reviews were performed by a different individual than the one responsible for preparing monthly financial reporting, calculations of per-unit activity, and requests for reimbursement. Planned Corrective Action: 1. Standardization of Fina...
Condition: The Organization lacked adequate controls to ensure reviews were performed by a different individual than the one responsible for preparing monthly financial reporting, calculations of per-unit activity, and requests for reimbursement. Planned Corrective Action: 1. Standardization of Financial Reporting Workflow: A formal segregation of duties for all federal and pass-through reimbursement requests and financial reports has been implemented. Effective immediately, the individual responsible for accumulating cost data and calculating per-unit activity (preparer) is prohibited from being the reviewer. 2. Implementation of Approval Process: All reports must now be submitted by the preparer to the designated reviewer for approval via email prior to submission. An approval response from the reviewer is required prior to submission to the awarding agency. 3. Staff Training: All grants management and accounting personnel have been briefed on the requirements of 2 CFR 200.303, specifically regarding the necessity of documented internal controls to provide reasonable assurance of compliance. Contact person responsible for corrective action: Erin Nordmann (Controller) Chiyoko Yokota (Chief Financial Officer) Anticipated Completion Date: Fully Corrected
Recommendation The Municipality must establish and implement a documented reconciliation process between the MIP and ORACLE accounting systems to ensure the accuracy and reliability of financial information used for federal compliance purposes. In addition, implement oversight procedures and periodi...
Recommendation The Municipality must establish and implement a documented reconciliation process between the MIP and ORACLE accounting systems to ensure the accuracy and reliability of financial information used for federal compliance purposes. In addition, implement oversight procedures and periodic monitoring to review and verify the WIOA expenditures to ensure they comply with the earmarking percentage limitations. View of responsible officials Management concurs with the findings as presented and notes that all corrective measures are already substantially implemented. The Municipality remains fully committed to maintaining strong internal controls and continuous improvement in federal grant administration. Responsible official Ana Maria Delgado WIOA Program Fiscal Agent Estimated completion date June 30, 2026
Finding 2025-003 See response to finding 2025-001.
Finding 2025-003 See response to finding 2025-001.
Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across dep...
Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across departments and teams. Finance will continue implementing the corrective actions necessary to establish an effective and compliant time and effort reporting system, including providing training for employees and regularly monitoring for effective system utilization. These actions will strengthen internal controls and ensure personnel costs are accurately recorded and appropriately allocated. The anticipated completion date remains June 30, 2027.
Reconciliations and Material Adjustments UMHS' acting Chief Executive Officer (CEO) was also the Chief Financial Officer (CFO) until October 2025 when a Finance Director was added. The Finance Director has an accounting degree, a master's in business administration (MBA), and is a licensed Certified...
Reconciliations and Material Adjustments UMHS' acting Chief Executive Officer (CEO) was also the Chief Financial Officer (CFO) until October 2025 when a Finance Director was added. The Finance Director has an accounting degree, a master's in business administration (MBA), and is a licensed Certified Public Accountant (CPA) with over 30 years' accounting and management experience. UMHS also retained the Payroll and Fund Accounting Manager who was on leave for 3 months in 2025. A replacement for the Fund Accounting Manager who passed away in February 2026 is also in progress. Many improvements to the Finance department have been implemented Since October 2025 including: a. Establishing department goals focusing on catching up on all required accounting activities including all reconciliations b. Removing the burdensome procurement requisition process when all the required purchase orders (POs) elements are completed and documented allowing more Finance to focus on core financial activities c. Planning for moving purchasing from the Finance department back to Operations to help focus Finance on core accounting activities d. Updating policies e. Drafting (approximately 10) formal and detailed procedures for all key/material activities f. Updating the Cost Allocation Plan g. Improving grant financial information/reports to Program Directors and Managers h. Submitting claims/draws to grantors before payroll is paid out and allocating out indirect (Admin) costs to grants allowing reimbursement through drawdowns/claims 45-60 days earlier for improved cash flow i. Several other changes for improved transparency and tracking Person responsible: Matthew Solomon
Finding 2025-004: Reporting – Owner – Certified Submission Management Response Management agrees with the finding. REAC submission was late because year – end accounting records were not done in time. Corrective Action Plan 1. Establish a Closing Calendar and Compliance Calendar • Year-end data dead...
Finding 2025-004: Reporting – Owner – Certified Submission Management Response Management agrees with the finding. REAC submission was late because year – end accounting records were not done in time. Corrective Action Plan 1. Establish a Closing Calendar and Compliance Calendar • Year-end data deadlines • Dates for draft and final financials • REAC submission due date 2. Coordination with Fee Accountant • Schedule year-end preparation work earlier • Fee Accountant set a deadline for LHA to provide supporting documents IMPLEMENTATION TIMELINE: PRIOR TO NEXT FISCAL YEAR-END.
Finding 2025-003 Replacement Reserves Management Response Management agrees with the finding. Excess deposits, incorrect posting of a reserve transfer and an unapproved withdrawal occurred due to inadequate oversight and incomplete reconciliation procedures. Corrective Action Plan 1. Deposit and Wit...
Finding 2025-003 Replacement Reserves Management Response Management agrees with the finding. Excess deposits, incorrect posting of a reserve transfer and an unapproved withdrawal occurred due to inadequate oversight and incomplete reconciliation procedures. Corrective Action Plan 1. Deposit and Withdrawal Controls • LHA has made an invoice for each month deposit • All withdrawals will be required written HUD approval and retention of documentation in a secured file 2. Monthly Reserve Account Verification • Review all deposit and withdrawal activity • Confirm no transfers were made to other program reserve accounts • Immediately request return of incorrectly transferred funds 3. HUD Follow-up • Contact HUD to determine required corrective steps for the unapproved withdrawal. IMPLEMENTATION TIMELINE: WITHIN 60 DAYS
Contact Person: Jeremy Teetor, Chief Financial Officer Corrective Action Plan: The finding resulted primarily from significant turnover within the Finance Department. Management has established procedures to ensure that all bank account and other required reconciliations are prepared on a timely bas...
Contact Person: Jeremy Teetor, Chief Financial Officer Corrective Action Plan: The finding resulted primarily from significant turnover within the Finance Department. Management has established procedures to ensure that all bank account and other required reconciliations are prepared on a timely basis going forward. The Finance department will also strive to keep key positions filled at all times and ensure that staff receives appropriate training regarding reconciliations. Proposed Completetion Date: Immediately
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordan...
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the University evaluate its policies and procedures around reporting student status changes to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: La Salle contractually relies on the National Student Clearinghouse (NSC) to conduct its enrollment reporting to NSLDS. While there has been closer adherence to the overall transmission schedule established with the NSC, and this covers enrollment reporting for the vast majority of our registered students, such was not always the case in prior semesters, and selected exceptional registration transactions are not directly reported when they actually occur, resulting in delays, until the next regularly scheduled transmission. Going forward, upon encountering these exceptional transactions, we will take steps to ensure reporting of individual enrollments to the NSC within 1-2 business days following the transaction’s occurrence. Name(s) of the contact person(s) responsible for corrective action: Gerard Donahue, Registrar Planned completion date for corrective action plan: Corrected as of Spring 2026 (Fall 2025 is already complete as of this writing)
Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures that ensure grant funds are...
Noncompliance/Material Weakness in Internal Control over Compliance: • Provide grants management training to all its financial staff and management covering the Uniform Guidance/OMB Guidance for Federal Financial Assistance. • Develop and implement policies and procedures that ensure grant funds are drawn at the time of, or following, expenditures for allowable costs. These policies and procedures will include that, for each draw from a Federal award, 1) detailed documentation of the expenditures for which the grant funds are being drawn is prepared prior requesting the draw, including transactional details such as vendor, invoice number, invoice amount, check number, check date, payee, and check amount; 2) that the documentation supporting the draw is reviewed and approved by a member of management (other than the person who prepares the documentation) prior to requesting the draw, and 3) that the documentation supported each draw is maintained as part of the Organization's accounting records. • Return H8F funds, including interest, to the Federal grantor agency.
Lack of Segregation of Duties in Financial Reporting - Compliance Recommendation: Management should reassign responsibilities so that the preparation, review and submission of required reports is performed by different individuals. If staffing limitations prevent full segregation, compensating contr...
Lack of Segregation of Duties in Financial Reporting - Compliance Recommendation: Management should reassign responsibilities so that the preparation, review and submission of required reports is performed by different individuals. If staffing limitations prevent full segregation, compensating controls, such as periodic independent reviews by a supervisor or board member, should be implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Due to staffing limitations, the organization has not been able to implement the optimal level of oversight. Going forward, all reports prepared by the Accountant will undergo a formal review and approval process by the Treasurer to strengthen internal controls and ensure appropriate oversight. Names of the contact persons responsible for corrective action: Robert Loiseau, Finance Director and Gary Beaulieu, Executive Director
Material weakness in internal control over compliance - Lack of control over monitoring of excess costs Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of excess costs during the year. Program staff and business office personnel will meet regula...
Material weakness in internal control over compliance - Lack of control over monitoring of excess costs Planned Corrective Action: The District is developing procedures to adequately monitor the calculation of excess costs during the year. Program staff and business office personnel will meet regularly to identify any potential issues for noncompliance with excess costs and develop a plan accordingly to ensure compliance is met. Staff training and utilization of the calculation tools provided by TEA will be provided to ensure all involved gain the necessary understanding. Responsible Contact Person: Farrah Jernigan, Chief Financial Officer Anticipated Completion Date: June 30, 2026
Finding 2025-001: Name of Contact Person: Joshua Stutts & Alanna Burkhart Corrective Action/Management Response: The Agency acknowledges nine instances of claims entered in EPI where adequate case documentation was not maintained. Nine case files did not include a signed form 1682. 1. The agency ack...
Finding 2025-001: Name of Contact Person: Joshua Stutts & Alanna Burkhart Corrective Action/Management Response: The Agency acknowledges nine instances of claims entered in EPI where adequate case documentation was not maintained. Nine case files did not include a signed form 1682. 1. The agency acknowledges findings of three instances of claims entered into EPI where adequate case documentation was not maintained due to staff turnover. 2. Current vacancy for Income Maintenance Investigator II position will be filled by December 1, 2025. 3. Train new staff on the revision of Program Integrity training curriculum beginning by December 31, 2025, and will be completed by June 30, 2026. A copy of the training program curriculum will be available for review. Proposed Completion Date: December 31, 2025
Recommendation: We recommend the Organization develop and implement a formal SEFA preparation policy that includes: - A centralized tracking system for all federal and pass-through awards, including subaward documentation - Review of the draft SEFA by another individual with knowledge of Federal rep...
Recommendation: We recommend the Organization develop and implement a formal SEFA preparation policy that includes: - A centralized tracking system for all federal and pass-through awards, including subaward documentation - Review of the draft SEFA by another individual with knowledge of Federal reporting requirements and grants received. Additional training on Uniform Guidance requirements would also be beneficial Action Taken: Accounting will implement a formal SEFA preparation process that includes the development of a centralized schedule to track direct and pass-through federal funding sources. The schedule will incorporate key data fields necessary to support SEFA reporting and compliance, including identification of pass-through entities and applicable expenditure thresholds. A formal review process will be implemented to provide for appropriate separation of duties, with one individual responsible for preparation and a separate individual responsible for review and approval.
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