Corrective Action Plans

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Student Financial Assistance Cluster – CFDA No. 84.063, 84.268 Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: No disagreement with the au...
Student Financial Assistance Cluster – CFDA No. 84.063, 84.268 Recommendation: We recommend the College review its procedures to ensure controls are in place to ensure to catch any inconsistencies that occur during the year. Explanation of disagreement with audit finding: No disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will maintain documentation of monthly communication between the External Programs Manager, the Financial Aid Director and the Director of Accounting, related to the monthly reconciliation of Federal Direct Loans, Federal Pell Grant. Federal SEOG and Federal Work Study programs. Name of the contact person responsible for corrective action: Jenae Schmidt, Director of Financial Aid Planned completion date for corrective action plan: September 30, 2025
Finding Reference Number: 2025-001 Return to Title IV Funds Summary of Finding: During the R2T4 calculation, all Title IV funds from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs that were disbursed or able to be disbursed should have be inc...
Finding Reference Number: 2025-001 Return to Title IV Funds Summary of Finding: During the R2T4 calculation, all Title IV funds from the Direct Loan, Federal Pell Grant, Iraq and Afghanistan Service Grant, TEACH Grant, and FSEOG programs that were disbursed or able to be disbursed should have be included in determining the amount of earned Title IV funds. In performing the calculation for one student, the institution failed to include all applicable federal aid resulting in $220 of excess Pell grant funds being retained on the student’s behalf. The excess funds of $220 were returned to the DOE in July 2025. Entity’s Corrective Action Plan: The University recognizes the importance of accuracy when performing R2T4 calculations. In this particular situation, the employee who performed the calculation was new in the role and had not previously had responsibility for R2T4 calculations. The University has reassigned this responsibility and has provided education and training for the staff responsible for R2T4 calculations for 2025-26. In addition, the University is requiring a review of each calculation by another member of the financial aid staff with knowledge and training on how to perform the calculations. Anticipated Completion Date: September 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services
View Audit 371188 Questioned Costs: $1
Finding Reference Number: 2025-002 Working During Scheduled Class Time Summary of Finding: Students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from att...
Finding Reference Number: 2025-002 Working During Scheduled Class Time Summary of Finding: Students are not permitted to work in Federal Work Study positions during scheduled class times. Exceptions are permitted if an individual class is cancelled, if the instructor has excused the student from attending for a particular day, and if the student is receiving credit for employment in an internship, externship, or community workstudy experience with exemptions being appropriately documented. The University had a few instances in which appropriate documentation for exemptions had not been obtained by the supervisors. The known error is $99 with extrapolation of the error across the population at $3,115. Entity’s Corrective Action Plan: The University understands the federal guidelines and provided reminders to all students and supervisors, via email, that students are not permitted to work during scheduled class times; the reminders were sent at the end of each pay period throughout the 2024-25 year. In August 2025, the University provided a required training session for all work study supervisors and reviewed the importance of compliance with this specific aspect of managing FWS as well as all other federal requirements governing the Federal Work Study Program. Supervisors and students continue to receive bi-monthly reminders of this policy. Supervisors are expected to monitor when their students are working and to know their students’ class schedules. They are expected to request documentation if clock-in times, or any period of their work shift, falls within a scheduled class time. Additionally, for 2025-26, the Human Resource Office is developing a review process to determine that appropriate documentation has been obtained if a student meets one of the eligible exemption criteria. Anticipated Completion Date: November 1, 2025 Name and Title of Responsible Person: Gus Morgan, Interim Financial Aid Director and VP for Enrollment Services and Rebecca Proffitt, Payroll and Student Employment Coordinator
View Audit 371188 Questioned Costs: $1
Recommendation: The Project should review the HUD agreement and approved budget to obtain a better understanding of the type of costs that are allowable, and ensure they are only using HUD funds for allowable costs. Planned Corrective Actions: High Street Homes, Inc. concurs with this finding. The q...
Recommendation: The Project should review the HUD agreement and approved budget to obtain a better understanding of the type of costs that are allowable, and ensure they are only using HUD funds for allowable costs. Planned Corrective Actions: High Street Homes, Inc. concurs with this finding. The questioned costs resulted from staff unfamiliarity with the HUD agreement due to turnover in the Finance Department. Corrective measures taken include: • Reimbursement of the unallowable costs identified ($2,261) with non-federal funds. • Ongoing training for Finance staff regarding HUD cost principles, allowable costs, and budget compliance. • Regular review of expenditures by the Director of Finance to ensure costs are reasonable, necessary, and allowable under the HUD agreement. These corrective actions will strengthen compliance with HUD cost requirements and prevent future occurrences.
View Audit 371113 Questioned Costs: $1
Need Analysis Planned Corrective Action: 1. A revised internal procedure has been implemented, requiring a secondary review of all loan award allocations prior to disbursement to confirm compliance with federal regulations. 2. Staff members responsible for loan origination and packaging have been as...
Need Analysis Planned Corrective Action: 1. A revised internal procedure has been implemented, requiring a secondary review of all loan award allocations prior to disbursement to confirm compliance with federal regulations. 2. Staff members responsible for loan origination and packaging have been assigned refresher training on federal loan awarding requirements, with specific emphasis on annual and aggregate loan limits and the prioritization of subsidized eligibility. 3. System-level reports have been created to identify potential discrepancies in loan allocation, which will be reviewed monthly by the Financial Aid Office. Ongoing Monitoring: The Director of Financial Aid will oversee the monitoring process each term to ensure compliance with 34 CFR 685.203, and 34 CFR 685.301 requirements. Any discrepancies identified will be corrected immediately and documented as part of the institution’s internal compliance log. North Greenville University believes these corrective measures address the issue identified and will prevent recurrence of similar errors. Person Responsible for Corrective Action Plan: Cindi Patterson, Director of Financial Aid Anticipated Date of Completion: October 1, 2025
Need Analysis Corrective Action Plan: The Office of Financial Aid & Scholarships (OFAS) will do the following: • Correct the procedures for data entry in Workday. • Revise internal procedures to review loan awards prior to disbursement. • Explore/implement system checks in Workday to flag potential ...
Need Analysis Corrective Action Plan: The Office of Financial Aid & Scholarships (OFAS) will do the following: • Correct the procedures for data entry in Workday. • Revise internal procedures to review loan awards prior to disbursement. • Explore/implement system checks in Workday to flag potential over-awards. • Conduct random reviews of aid packages to ensure compliance. • Document system changes and over-award resolution. Person Responsible for Corrective Action Plan: Mike Sapienza, Senior VP for Enrollment Services Anticipated Date of Completion: May 31, 2026
View Audit 370986 Questioned Costs: $1
MANAGEMENT AGREEMS WITH THE FINDING. THE FUNDS WILL BE REIMBURSED.
MANAGEMENT AGREEMS WITH THE FINDING. THE FUNDS WILL BE REIMBURSED.
View Audit 370975 Questioned Costs: $1
MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT HAS SUBMITTED THE FORMS FOR HUD'S APPROVLA.
MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT HAS SUBMITTED THE FORMS FOR HUD'S APPROVLA.
View Audit 370975 Questioned Costs: $1
MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT HAS SUBMITTED THE FORMS FOR HUD'S APPROVAL
MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT HAS SUBMITTED THE FORMS FOR HUD'S APPROVAL
View Audit 370974 Questioned Costs: $1
Re: Response to Reference Number 2025-001 Student Financial Aid Cluster View of Responsible Officials: Comments on Finding and Recommendation The University agrees that the Bursar's office did not refund the student credit balances within the 14-day requirement. One was $19.10 and was missed due to ...
Re: Response to Reference Number 2025-001 Student Financial Aid Cluster View of Responsible Officials: Comments on Finding and Recommendation The University agrees that the Bursar's office did not refund the student credit balances within the 14-day requirement. One was $19.10 and was missed due to human error in filtering refunds under $25. The second was for $800.00 and was refunded 10 days late. Corrective Action Plan for Reference Number 2025-001 Student Financial Aid Cluster The University Controller and CFO provided additional training and guidance to Bursar's office staff regarding the importance of the 14-day refund requirement on September 11 , 2025. An additional verification step has been added to their weekly refund routine : on Fridays, after the weekly refunds have been processed, they will now review the student aging report and investigate credit balances to verify that no one has been missed and that the University remains in compliance. Mid-America Christian University's Controller, Kim Brock, will be responsible for ensuring this corrective action plan is followed as outlined . Kim can be reached at kim.brock@macu.edu or 405-703-8269.
To safeguard from future errors and ensure data accuracy, Human Resources partnered with Enterprise Application Services department to develop an automated process that populates earnings codes and project account codes based on employee, job record and earnings code. This enhancement streamlines da...
To safeguard from future errors and ensure data accuracy, Human Resources partnered with Enterprise Application Services department to develop an automated process that populates earnings codes and project account codes based on employee, job record and earnings code. This enhancement streamlines data entry by consolidating it into a single interface, reducing the risk of manual entry errors. Additionally, the HR Technology Manager has implemented a new monitoring report to track employees with multiple salary distribution accounts as a part of payroll process. The biweekly report will be automatically generated and sent via email to HR’s HRIS Consultants for review. The HRIS Consultants will analyze the report, resolve any discrepancies and escalate any issues to the HR Technology Manager or Lead Application Consultant as necessary. These processes will be routinely reviewed, with adjustments made as needed.
View Audit 370942 Questioned Costs: $1
The University has found a critical breakdown in communication between the Ranch Management department and the Registrar’s Office, stemming from informal, ad hoc processes that have not scaled with institutional needs. Specifically, there is no formal mechanism to ensure that updates to student stat...
The University has found a critical breakdown in communication between the Ranch Management department and the Registrar’s Office, stemming from informal, ad hoc processes that have not scaled with institutional needs. Specifically, there is no formal mechanism to ensure that updates to student statuses for the ranch management program are consistently reported or verified. To prevent recurrence of this issue, a process is being implemented that all Non-Degree programs will now be required to perform formal degree audits within the student information system. This ensures consistency in processing and aligns with practices currently used for degree-seeking students. Targeted training and communication will be provided to all Non-Degree program administrators to ensure clarity on new expectations, tools, and timelines. The Registrar’s Office will conduct periodic audits of non-degree program records to verify compliance and identify any further process improvements.
View Audit 370942 Questioned Costs: $1
Single AUdit Report for 2024-2025 Reference/Finding Number 2025-001 Management's Planned Corrective Action Management acknowledges and understands the finding associated with Eligibility. The student's Pell award has already been corrected and accepted by COD. Management is working with IT to automa...
Single AUdit Report for 2024-2025 Reference/Finding Number 2025-001 Management's Planned Corrective Action Management acknowledges and understands the finding associated with Eligibility. The student's Pell award has already been corrected and accepted by COD. Management is working with IT to automate the enrollment change report to be sent on a weekly basis to validate that all increases in hours have been appropriately updated and processed. This will also become part of our required annual reconciliation process of the Pell grant program. Responsible Official Bridget Moore Director of Student Financial Services Abilene Christian University Estimated Completion Date July 24, 2025
View Audit 370836 Questioned Costs: $1
CORRECTIVE ACTION PLAN Finding 2025-001 – Reporting The District concurs with the finding 2025-001. Corrective Action: Moving forward, the District Treasurer will enter the monthly claims with the Food Service Director and will verify that the meal counts and the total claims are correct for both br...
CORRECTIVE ACTION PLAN Finding 2025-001 – Reporting The District concurs with the finding 2025-001. Corrective Action: Moving forward, the District Treasurer will enter the monthly claims with the Food Service Director and will verify that the meal counts and the total claims are correct for both breakfast and lunch. The anticipated completion date of the corrective action is September 29, 2025. Contact Person: Alicia D. Koster, Superintendent of Schools (518) 762-4611 akoster@johnstownschools.org
View Audit 370819 Questioned Costs: $1
The Project implemented a new system in place to ensure all replacement reserve deposits are deposited within the audit period.
The Project implemented a new system in place to ensure all replacement reserve deposits are deposited within the audit period.
View Audit 370727 Questioned Costs: $1
Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 34 CFR Sections 690.8...
Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 34 CFR Sections 690.83(b)(2) and 685.309 Condition – Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately Questioned Costs – N/A Context – A total of 7 out of 40 students tested were noted to have at least 1 error in enrollment or program information reported to NSLDS within the required 60 days. Our sample was not, and was not intended to be, statistically valid. Effect – NSLDS was not notified of student status changes or program information in accordance with compliance requirements. Cause – The University did not have effective internal control processes in place to ensure the accurate collection, review, and reporting of student status changes occurred timely or accurately. The recent turnover in personnel resulted in a lack of oversight as well. Indication as a Repeat Finding – Yes Recommendation – The University should review its internal controls surrounding the enrollment reporting process and ensure internal controls provide for the timely and accurate reporting of student status changes. Views of Responsible Officials and Planned Corrective Actions – Tina Petersen, Registrar, will oversee the two-fold corrective action plan. First, we are immediately reviewing our degree posting policy and dates to create a more effective and standardized process. This policy review will enable us to properly assess any delayed completers and ensure that students are "completed" in our systems and reported to NSLDS in a more timely and accurate manner. Additionally, we are updating our formal, step-by-step written procedure manual for all enrollment reporting processes, with a specific focus on degree conferral and the subsequent reporting to NSLDS. This updated manual will serve as a crucial resource to ensure procedural consistency, especially during personnel changes. Second, we are enhancing our training protocols and internal controls. All staff members involved in the NSLDS reporting process will be required to attend mandatory, recurring training to ensure they are up-to-date on all compliance requirements. We will also implement a more robust system of checks and balances to verify the accuracy of the data before it is submitted to NSLDS. By taking these steps, the University is dedicated to improving its internal controls and fully remediating this finding. The corrective action plan will be implemented by November 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu
Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Disbursements to or on behalf of students, 34 CFR Section 668.164(h)(2) Con...
Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Disbursements to or on behalf of students, 34 CFR Section 668.164(h)(2) Condition – Students did not receive refunds within the required timeframe Questioned Costs – N/A Context – 7 out of 25 students tested received their credit balance refund more than 14 days after the credit balance was generated. All but 1 of these students received their refund within 16 days of the generation of the credit balance. Our sample was not, and was not intended to be, statistically valid. Effect – Noncompliance with federal regulations requiring timely disbursement of credit balance refunds Cause – Due to the high volume of credit balance refunds being processed, the University encountered operational constraints that prevented all refunds from being generated within the designated 14-day timeframe. Indication as a Repeat Finding – N/A Recommendation – To ensure timely refund of student credit balances, implement a control that flags any refund not processed before the end of the 14-day timeframe for immediate review and escalation. Additionally, establish a monitoring report to track refund timeliness weekly and reinforce accountability for processing within the required timeframe. Views of Responsible Officials and Planned Corrective Actions – Amy Schlup, Director of Student Financial Services, and Carrie Hamilton, Assistant Director of Financial Aid, will oversee the corrective action plan. As part of this process, they will review the daily Student Refund Report to identify and assist the personal financial counselor in expediting student refunds. The Student Financial Services team will also review and retrain on the proper procedures for processing refunds within the required timeframe. The corrective action plan is already in progress and will be fully implemented by October 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu
Corrective Action Plan (CAP for Finding 2025-001) Date: 2 October 2025 Responsible official: Frederick L. Clement, Executive Vice President Management has corrected the finding by taking the following action: First, the institution entered into a professional services agreement with Higher Education...
Corrective Action Plan (CAP for Finding 2025-001) Date: 2 October 2025 Responsible official: Frederick L. Clement, Executive Vice President Management has corrected the finding by taking the following action: First, the institution entered into a professional services agreement with Higher Education Assistance Group to provide a comprehensive business process review of its financial aid operations. The objective of this review is to improve upon the functionality of processes, internal controls, and systems to ensure regulatory compliance and the effectiveness of service deliverables to students receiving financial aid. This review will include updates to policies, procedures, and internal controls for the import and export of electronic records, document tracking and file review, packaging and awarding, satisfactory academic progress, disbursement and reconciliation, withdrawal and Return to Title IV. Workflow and gap analysis will be performed to ensure intraoffice Title IV program compliance and best practices. Second, the institution has entered into a professional services agreement with Higher Education Assistance Group to provide interim staffing and third-party federal student aid processing including, but not limited to, counseling students and families on financial aid options, assisting with the management of Federal Direct Loan and Federal Graduate PLUS Loan programs to include student eligibility, file review, awarding, and origination and disbursement authorization using Populi, COD and other Department of Education software. In addition, Higher Education Assistance Group will provide additional Title IV training for personnel involved in federal student aid processing. With more than 35 years of experience, Higher Education Assistance Group and its team of seasoned consultants, all of whom have worked in federal student aid administration, whether in public/private colleges and universities or for the Department of Education itself, specializes in the compliant administration of Title IV student financial aid programs. The institution will adopt a supplemental internal control to cross-check student eligibility for Direct PLUS loans to ensure that an over-award is not originated and disbursed. Anticipated completion date: November 15, 2025
View Audit 370654 Questioned Costs: $1
Auditors noted that for two of the six sampled students, funds were returned to ED more than 45 days after the date the University determined the student had withdrawn. For one selection, a Return of Title IV calculation was performed timely, but an administrative error caused the disbursement to be...
Auditors noted that for two of the six sampled students, funds were returned to ED more than 45 days after the date the University determined the student had withdrawn. For one selection, a Return of Title IV calculation was performed timely, but an administrative error caused the disbursement to be delayed eight months. For the second selection, the University was notified of withdrawal in early March 2025 and student was included in registrar’s withdrawal listing, but was missed in review by Student Financial Services until late April 2025. Contact Person(s): Vickie Rekov, VP Enrollment Services; Roger Wilson, Associate Director of Financial Aid, SFS; Ryan Porter, CFO and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: All employees in Student Financial Services and Accounting Office involved in the reporting, distribution, drawdown and return of federal funds have reviewed the criteria under 34 CFR 668.22 The two departments involved will be meeting in the month of September 2025 to review policies and procedures to ensure controls exist and are well documented to ensure funds are returned timely. In-charge personnel will gather training resources to educate those involved in the reporting, disbursement and return of Title IV Funds. Anticipated completion date: October 2025
The University drew down $72,265 in Federal Supplemental Educational Opportunity Grants (FSEOG) funds in October 2024 and disbursed funds to students through January 2025. No amounts were disbursed to students within the required three business days from receipt of funds, and no funds were returned ...
The University drew down $72,265 in Federal Supplemental Educational Opportunity Grants (FSEOG) funds in October 2024 and disbursed funds to students through January 2025. No amounts were disbursed to students within the required three business days from receipt of funds, and no funds were returned to ED. Contact Person(s): Vickie Rekov, VP Enrollment Services; Cynthia Kennedy, Director of SFS; Ryan Porter, CFO and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: All employees in Student Financial Services and Accounting Office involved in the reporting, distbursement and drawdown of federal funds have reviewed the criteria under 34 CFR 668.162 under the advance payment method. The two departments involved will be meeting in the month of September 2025 to review current process and procedures and make appropriate changes to meet these requirements. Anticipated completion date: September 30, 2025
View Audit 370626 Questioned Costs: $1
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs they failed to maintain the property. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response Management is working with HUD to ensure all exigent h...
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs they failed to maintain the property. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response Management is working with HUD to ensure all exigent health and safety issues are resolved by the completion date above. S3800-160 Contact Person First Name Amin S3800-180 Contact Person Last Name Akbar
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response On June 17, 2025, the Corporation entere...
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response On June 17, 2025, the Corporation entered into a purchase and sale agreement with The Christ Hospital to acquire the property for $1,485,528. Pending HUD approval. S3800-160 Contact Person First Name Amin S3800-180 Contact Person Last Name Akbar
View Audit 370591 Questioned Costs: $1
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response On June 17, 2025, the Corporation entere...
S3800-090 Auditor's Summary of the Auditee's Comments on the Finding and Recommendations The Corporation concurs that they did not pay the debt in full at maturity. S3800-130 Response Indicator Agree S3800-140 Completion Date April 30, 2026 S3800-150 Response On June 17, 2025, the Corporation entered into a purchase and sale agreement with The Christ Hospital to acquire the property for $1,485,528. Pending HUD approval. S3800-160 Contact Person First Name Amin S3800-180 Contact Person Last Name Akbar
View Audit 370591 Questioned Costs: $1
Summary of finding: Five out of 40 charts reviewed by the auditors’ showed exceptions to the Sliding Fee Discount Schedule (SFDS) that are not supported by policy or documentation. Findings were identified in three primary categories: inconsistent collection and scanning of documents at registration...
Summary of finding: Five out of 40 charts reviewed by the auditors’ showed exceptions to the Sliding Fee Discount Schedule (SFDS) that are not supported by policy or documentation. Findings were identified in three primary categories: inconsistent collection and scanning of documents at registration, Electronic Health Records (EHR) not operating as expected for one line of the SFDS and error not caught and corrected, and a significant process change from percentage to fixed fee SFDS causing inconsistent application during transition and training period. Planned corrective action: System Configuration:  Leaders for all service lines and Billing Department will work with EHR Support Team and vendor to review and test all possible SFDS options to verify rules are functioning as expected and as outlined in the SFDS policy.  Annual review and testing of EHR rules governing SFDS to validate ongoing compliance. Contact person: Jennifer Velez, Revenue Cycle Director Completion date for action: 10/31/2025 Staff Training and Documentation:  All staff responsible for registration and income verification in all service lines, programs, and sites will receive a review of income eligibility assessment, documentation, and application.  Registration Program Manager and EHR Trainers will work with Learning and Development Department to develop competency standard for income eligibility assessment, documentation, and application for all staff responsible for registration and income verification in all service lines, programs, and sites. All identified staff will be required to demonstrate competence annually using the Learning Management System (LMS).  The Center will audit 5 patient records for FPL (Federal Poverty Level) documentation per site or program two times annually during C-Qual (the Center’s internal audit process). This will result in 180 charts each year.  Site Managers or Department Administrators will review front office dashboard in monthly management meetings and develop site specific action plans if exceptions are identified. This was added to the standing agenda for the Primary Care Clinic Managers (PCCM) meeting in September 2025. Contact person: Angela Hurley, Director of Operations Completion date for action: 12/31/2025 Implementation Controls:  Update SFDS policy to include review and verification of EHR alignment with fee schedule following any update or change approved by the Board of Directors.  Develop checklist for roll-out of changes in SFDS that prompts change management and training team to review readiness and validation procedures before going live with changes. Contact person: Angela Hurley, Director of Operations Completion date for action: 9/30/2025
Finding 2025-002 Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditors’ finding. Corrective Action Pending Anticipated Completion Date July 15, 2025
Finding 2025-002 Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditors’ finding. Corrective Action Pending Anticipated Completion Date July 15, 2025
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