Corrective Action Plans

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Federal Programs: Student Financial Assistance (SFA) Cluster - Various ALN COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Compliance Requirement – Cash Management Management’s Response The UPR concurs with this finding. In two instances, UPR requested funds to G5 with too much ...
Federal Programs: Student Financial Assistance (SFA) Cluster - Various ALN COVID-19 Higher Education Emergency Relief Fund (HEERF) - 84.425 Compliance Requirement – Cash Management Management’s Response The UPR concurs with this finding. In two instances, UPR requested funds to G5 with too much time in advance. The central administration finance office asked for all units' payment schedules. We will review them and, if necessary, request that schedules include the date to request funds to G5 and the payment date. Schedules must be approved and signed by a finance director’s representative. Staff from the financial aid, fiscal affairs, finance, and disbursement offices will be trained on the FSA Handbook, specifically about requesting and managing FSA funds. We will discuss potential errors that may occur during the process and how, as a group, they can monitor and prevent missed payment deadlines. For example, if the finance office receives G5 funds before the scheduled date, the payment date to students must be brought forward. This type of monitoring and awareness of potential non-compliance should result in compliance with the regulations. Responsible Person or Office: Finance office at the central administration and finance offices at the eleven (11) institutional units. Timeline: 2025-2026
Corrective Action Plan For the Year Ended June 30, 2024 Finding: 2024-003 Name of contact person: Corrective action: Proposed completion date: Section IV - State Award Findings and Question Costs Corrective Actions for Finding 2024-002 and 2024-003, also apply to the State findings. Training was com...
Corrective Action Plan For the Year Ended June 30, 2024 Finding: 2024-003 Name of contact person: Corrective action: Proposed completion date: Section IV - State Award Findings and Question Costs Corrective Actions for Finding 2024-002 and 2024-003, also apply to the State findings. Training was completed on 10/17/2024 by the Adult Medicaid Supervisors and Family & Children Supervisors. Adult Medicaid and Family & Children Medicaid Supervisors will begin monthly unit group training starting January 2025. Training focus will be on error findings for past and current audit findings, as well as policy refreshers. Additional training topic will be added as needed. Section III - Federal Award Findings and Question Costs (continued) Shaneall Kollock, Medicaid Program Manager Adult Medicaid Supervisors have trained staff on policies MA-2300 Applications and MA-2230 Financial Resources. Family & Children's Medicaid Supervisors have trained staff on policy MA-3200 Applications.Supervisors have also reviewed with staff verification of evidence, documentation, electronic sources(TWN, ROD, Tax Office). Supervisors will regularly monitor and check random applications/cases for inadequate request for information and evidence verifications. Any staff with error issues will complete additional training with Supervisors and/or Lead Workers. Any issues with staff making continuous errors and/or showing no improvement will lead to possible disciplinary conferences. 118
Finding: 2024-002 Name of contact person: Corrective action: Proposed completion date: Shaneall Kollock, Medicaid Program Manager Adult Medicaid Supervisors have trained staff on policies MA-2300 Applications and MA-2230 Financial Resources. Supervisors completed individual training with each staff ...
Finding: 2024-002 Name of contact person: Corrective action: Proposed completion date: Shaneall Kollock, Medicaid Program Manager Adult Medicaid Supervisors have trained staff on policies MA-2300 Applications and MA-2230 Financial Resources. Supervisors completed individual training with each staff member to ensure verification of evidence, application/case documentation, and electronic sources are completed . Supervisors and Lead Workers will regularly monitor applications/cases for inaccurate resource entry. Caseworkers have been informed all evidence must have supported verifications scanned and documented in NCFAST. Any staff with error issues will complete additional training with the Supervisors and/or Lead Workers. Any issues with staff making continuous errors and/or showing no improvement will lead to possible disciplinary conferences. Corrective action: The Finance Director has made modifications to the internal year-end audit preparation procedures. With these modifications in place the director feels that the audit can be completed in a timely manner moving forward. Section III - Federal Award Findings and Question Costs Training was completed on 10/17/2024 by Adult Medicaid Supervisors. Adult Medicaid Supervisors will begin monthly unit group training starting January 2025. Training focus will be on error findings for past and current audit findings, as well as policy refreshers. Additional training topic will be added as needed.
Finding 553636 (2024-002)
Significant Deficiency 2024
SIGNIFICANT DEFICIENCY 2024-002 Crime Victim Assistance -Assistance Listing No. 16.575 Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG...
SIGNIFICANT DEFICIENCY 2024-002 Crime Victim Assistance -Assistance Listing No. 16.575 Recommendation: The Organization should continue to apply its current procurement policy to new and existing vendors to ensure proper documentation is retained in accordance with said procurement policy and SA UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will apply its current procurement policy to new and existing vendors in order to comply with applicable procurement requirements. Name(s) of the contact person(s) responsible for corrective action: Tracy Johnson, Director of Finance Planned completion date for corrective action plan: June 30, 2025
Finding 2024-002 Condition: Three vendors were awarded a contract without a competitive procurement process. Corrective Action Planned: The district will implement controls to ensure that the all federal grants have the higher standard of the federal procurement, which is above the MGL Chapter 30B...
Finding 2024-002 Condition: Three vendors were awarded a contract without a competitive procurement process. Corrective Action Planned: The district will implement controls to ensure that the all federal grants have the higher standard of the federal procurement, which is above the MGL Chapter 30B exemption to special education services, applied to federal grant spending. All efforts for quotes for contracted services will be memorialized in a memo to the Director of Finance and Operations prior to execution of contracts. Anticipated Completion Date: By July 1, 2025 Contact: Ross Mulkerin, Director of Finance and Operations
View Audit 352205 Questioned Costs: $1
Finding 2024-001 Condition: Costs were recorded for service periods prior to grant approval date. Corrective Action Planned: The district will implement controls to prevent the recording of costs for service periods prior to grant approval date by written guidance to all staff involved in federal ...
Finding 2024-001 Condition: Costs were recorded for service periods prior to grant approval date. Corrective Action Planned: The district will implement controls to prevent the recording of costs for service periods prior to grant approval date by written guidance to all staff involved in federal grant funds. Please note, that the practice at question is not in violation of school committee policy as we have not made any expenditures outside that entity’s approval date. Anticipated Completion Date: By July 1, 2025 Contact: Ross Mulkerin, Director of Finance and Operations
View Audit 352205 Questioned Costs: $1
U.S DEPARTMENT OF COMMMERCE COVID-19-Economic Development Administration- CARES RLF - Assistance Listing No. 11.307, Grant period - Year ended June 30, 2024. See finding 2024-002 – listed below. ALLOWANCE FOR UNCOLLECTIBLE LOANS Recommendation: When management determines a loan is uncollectible, the...
U.S DEPARTMENT OF COMMMERCE COVID-19-Economic Development Administration- CARES RLF - Assistance Listing No. 11.307, Grant period - Year ended June 30, 2024. See finding 2024-002 – listed below. ALLOWANCE FOR UNCOLLECTIBLE LOANS Recommendation: When management determines a loan is uncollectible, they should ensure an allowance is recorded. Management Response: Management concurs with finding. Planned Corrective Action: The Finance Department will include the Fiscal Manager and Fiscal Controller in any communications regarding problematic loans to ensure proper reporting. Persons Responsible: Jamie Carnes, Fiscal Controller Anticipated Completion Date: March 31, 2025.
Finding 2024-02: Indirect Costs (IDC) Views of Responsible Officials Management agrees with the finding and recommendations. Through the merger with Old Dominion University, additional controls have adopted around the processes and controls around the accuracy of the review over indirect costs calcu...
Finding 2024-02: Indirect Costs (IDC) Views of Responsible Officials Management agrees with the finding and recommendations. Through the merger with Old Dominion University, additional controls have adopted around the processes and controls around the accuracy of the review over indirect costs calculation requirements. Corrective Action Plan Effective July 1, 2024, EVMS merged with ODU and the ODU Research Foundation became the fiscal and administrative agent for EVMS’s transferring sponsored programs on behalf of ODU. As per ODU’s Memorandum of Understanding (MOU) with the ODU Research Foundation, the ODU Research Foundation has policies and processes in place to manage how the indirect costs are calculated. The ODU Research Foundation uses its own system of internal controls for IDC calculation with no reliance on ODU systems for those processes and are audited separately. As a corrective action moving forward, ODU management will notify the ODU Research Foundation management of the audit findings, so they are aware of the internal control deficiencies. ODU will request the Research Foundation to provide a copy of their single audit report to monitor continued compliance with Uniform Guidance. The corrective action plan will be completed by March 31, 2025 and the contact person for this finding is Victoria Dean.
View Audit 352191 Questioned Costs: $1
Finding 553586 (2024-002)
Significant Deficiency 2024
Name of contact person: Melissa Labra, Income Maintenance Administrator II Case workers will receive additional training on countable/non-countable resources. Workers will be reminded of the procedures and policies that should be followed at time of application and recertification processes. Superv...
Name of contact person: Melissa Labra, Income Maintenance Administrator II Case workers will receive additional training on countable/non-countable resources. Workers will be reminded of the procedures and policies that should be followed at time of application and recertification processes. Supervisors will conduct second party reviews on applications and recertification’s to determine that proper policies and procedures are being followed. Workers will be retrained on NCFAST evidence for resources to ensure procedures are being followed for evidence on dashboard to match the supporting documentation used as verifications. Supervisors will review cases to verify that evidence in NC FAST and supporting documentation match. Proposed Completion Date: January 31, 2026
View Audit 352178 Questioned Costs: $1
Finding 553585 (2024-001)
Significant Deficiency 2024
Name of contact person: Melissa Labra, Income Maintenance Administrator II Corrective Action: Caseworkers will receive additional training on complete documentation in case files, application of NCFAST evidence including accurate needs unit, precise resource calculations and countable/non-countable ...
Name of contact person: Melissa Labra, Income Maintenance Administrator II Corrective Action: Caseworkers will receive additional training on complete documentation in case files, application of NCFAST evidence including accurate needs unit, precise resource calculations and countable/non-countable resources. Caseworkers will receive additional training in regards to the proper procedures and policies that should be followed at time of application and recertification process. Supervisors will conduct second party reviews on applications and recertification’s to determine that the correct procedures are being followed. Caseworkers will receive training on the work number (TWN) in NCFAST learning gateway. Caseworkers will receive training on income and budgeting policy (MA 3300). Caseworkers will receive training on third party insurance and inputting such into NC FAST. Supervisors will review cases to verify evidence and supporting documentation match and cases show consistency. Supervisors will review cases to ensure evidence is inputted correctly and accurate needs units is used in determination of benefits. Proposed Completion Date: January 31, 2026
Management’s Response/Corrective Action Plan: This program received significantly more distributions in 2024 than the City had received in the past. The funds initially were not considered to be federal since the source was private companies, but staff has since taken required grant agency training...
Management’s Response/Corrective Action Plan: This program received significantly more distributions in 2024 than the City had received in the past. The funds initially were not considered to be federal since the source was private companies, but staff has since taken required grant agency training. The City is implementing workflow for purchasing and credit card transactions which will provide electronic approvals and the ability to attach receipts.
Management’s Response/Corrective Action Plan: Management will reconcile reimbursement requests to general ledger detail and review available grant amounts before submitting the drawdown.
Management’s Response/Corrective Action Plan: Management will reconcile reimbursement requests to general ledger detail and review available grant amounts before submitting the drawdown.
View Audit 352169 Questioned Costs: $1
Management’s Response/Corrective Action Plan: The Director and Operations Manager abruptly left in spring of 2024, leaving the Finance Department to take over all financial functions. The City contracted with Greater Portland Metro to run the service until we could determine next steps. The City Co...
Management’s Response/Corrective Action Plan: The Director and Operations Manager abruptly left in spring of 2024, leaving the Finance Department to take over all financial functions. The City contracted with Greater Portland Metro to run the service until we could determine next steps. The City Council approved joining Greater Portland Metro in September 2024, effective January 2025. The City no longer has a bus service.
Management’s Response/Corrective Action Plan: The Director and Operations Manager abruptly left in spring of 2024 and the City contracted with Greater Portland Metro to run the service until we could determine next steps. The City Council approved joining Greater Portland Metro in September 2024, e...
Management’s Response/Corrective Action Plan: The Director and Operations Manager abruptly left in spring of 2024 and the City contracted with Greater Portland Metro to run the service until we could determine next steps. The City Council approved joining Greater Portland Metro in September 2024, effective January 2025. The City no longer has a bus service.
Management’s Views and Corrective Action Plan Management response to finding 2024-004: Review over cost transfers of subrecipient expenditures Cluster Name: Research and Development Federal Awarding Agency: Various Award Name: Various Award Number: Various Award Years: Various Assistance Listing T...
Management’s Views and Corrective Action Plan Management response to finding 2024-004: Review over cost transfers of subrecipient expenditures Cluster Name: Research and Development Federal Awarding Agency: Various Award Name: Various Award Number: Various Award Years: Various Assistance Listing Title: Various Assistance Listing Number: Various Pass-through entities: Various As described in Finding 2024-004, and as a result of improper training related to the implementation of the university’s new financial system in FY22, the university lacked adequate controls to identify the proper application of indirect costs as it relates to subrecipient expenses when using the cost transfer process to make corrections. Additionally, the university failed to properly apply its policy for the classification of subawards versus direct expenditures. As such, while cost transfers are a small percentage of overall transfer activity, an update to training materials will be made by June 2025 to educate cost transfer initiators on the proper method to use for this subset of subrecipient expenditures. Since February 2025, the Sponsor Projects Accounting (SPA) representative responsible for central office review of cost transfers now reviews to ensure that all intended grant related attributes are in effect before approving any subrecipient cost transfers. Additionally, as of February 2025, the university reinforced its policy regarding the classification of subawards versus direct expenditures with both the Procurement department and the SPA staff to ensure the proper expenditure classification is set up during the onboarding process of a contractor. The SPA team has completed its analysis and review of all previous subrecipient cost transfers to verify and correct the improper application of indirect cost limits and expenditure classifications. As of March 2025, all subrecipient cost transfer errors have been identified and corrected, resulting in questioned costs of approximately $587,000. Separately, this resulted in an under-recovery of $306,000 of indirect costs that were not charged to the original award. As all awards impacted are still open and active, the correcting expenditure adjustments were applied to the awards impacted that will affect future draw downs. Contact Person: Cindy Lee, Director, Sponsored Projects Accounting, cmlee@usc.edu
Management’s Views and Corrective Action Plan Management response to finding 2024-003: Unallowable costs – Cost transfers based on budgeted amounts Cluster Name: Research and Development Federal Awarding Agency: Department of Health and Human Services Award Name: Leveraging natural phenotypic vari...
Management’s Views and Corrective Action Plan Management response to finding 2024-003: Unallowable costs – Cost transfers based on budgeted amounts Cluster Name: Research and Development Federal Awarding Agency: Department of Health and Human Services Award Name: Leveraging natural phenotypic variations of heterogenous ALS populations-in-a-dish to enable scalable drug discovery Award Number: 5R01NS131409-03 Award Years: 2022-2025 Assistance Listing Title: Extramural Research Programs in the Neurosciences and Neurological Disorders Assistance Listing Number: 93.853 Pass-through entities: Not applicable As described in finding 2024-003, the university inadvertently processed a cost transfer moving expenses from one grant to another based on budgeted figures instead of actual expenses incurred. This resulted in an amount transferred that was greater than the actual costs incurred. The administrator in question has been identified and further review of this administrator’s work has been performed to determine if additional instances occurred. Upon review of the administrator’s work, it was determined that no additional corrections were required as no other instances of this nature were identified outside of the total questioned costs. As part of the department’s efforts to minimize further cost transfer errors, training was provided to all their grant administrators beginning November 1, 2024. This training will now be held annually to ensure the department responsible for administering the award is current on the University’s existing compliance policies. Furthermore, to support accuracy and transparency, the department will allocate separate time commitments during weekly administration meetings to review any required cost transfers. This time will be dedicated to ensuring proper documentation is in place, confirming the appropriateness of the transfer, and ensuring full compliance of the transaction(s). This updated review process involves representatives from Grant Administration, Keck School of Medicine Finance Office, and Purchasing, to ensure a full comprehensive review of each transfer. As such, beginning November 2024, a cost transfer will not move forward until it has been reviewed by the group. Contact Person: Andres Chan, Director, FBS Financial Analysis, andres.chan@usc.edu
View Audit 352166 Questioned Costs: $1
Management’s Views and Corrective Action Plan Management response to finding 2024-002: Unallowable costs over the NIH salary cap Cluster Name: Research and Development Federal Awarding Agency: Department of Health and Human Services Award Name: Alzheimer's Clinical Trial Consortium Award Number: ...
Management’s Views and Corrective Action Plan Management response to finding 2024-002: Unallowable costs over the NIH salary cap Cluster Name: Research and Development Federal Awarding Agency: Department of Health and Human Services Award Name: Alzheimer's Clinical Trial Consortium Award Number: 5U24AG057437-07 Award Years: 2023-2025 Assistance Listing Title: Aging Research Assistance Listing Number: 93.866 Pass-through entities: Not applicable As described in finding 2024-002, the process for manually creating sub-grants within our financial systems required an attribute to be activated. In this instance the attribute in question was not activated, resulting in the NIH salary cap restriction not to be enforced within the payroll system. In November 2024, when this instance was identified, a correction was immediately made to stop any future amounts above the salary cap to be charged to the award and to avoid any further errors. To ensure any transactions that occurred while the incorrect system attribute was in place were properly addressed, corrective measures in the form of cost transfers were made during this period by the department to minimize inappropriate charges to the sponsor. As part of the university’s corrective action plan, the Sponsored Project Accounting (SPA) office has completed a full review of all awards and determined this to be an isolated event. As of March 2025, to further strengthen internal controls over compliance, the SPA office has implemented a revised approach for the creation of new manual sub-grants which will ensure the necessary NIH salary cap restrictions are applied. Additionally, training documents have been updated to reflect this revised approach, and all SPA staff have now received training on this new update. Contact Person: Cindy Lee, Director, Sponsored Projects Accounting, cmlee@usc.edu
View Audit 352166 Questioned Costs: $1
Finding 553477 (2024-002)
Significant Deficiency 2024
"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Sup...
"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024 Criteria – Federal regulations governing Title IV programs. Condition – Non-compliances were noted, as more fully described in the context below. Questioned Costs – N/A Context – We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs 1) Three (3) out of 25 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). Cause – Oversight by responsible employees. Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable. Repeat Finding – No Auditor’s Recommendation – We strongly recommend the College refine the processes and procedures for the timely recording of disbursements in the general ledger allowing for more accuracy in financial reporting. View of Responsible Officials – The College has refined processes and procedures to ensure student refunds are processed within 14 days after the credit appears on the student account.
Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: Accounts Payable (AP) will create a Corrective Action plan to include the following. 1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the u...
Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: Accounts Payable (AP) will create a Corrective Action plan to include the following. 1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. 2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding 3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel. Anticipated Completion Date: December 31, 2025
View Audit 352153 Questioned Costs: $1
Finding 552320 (2024-011)
Significant Deficiency 2024
Name of Responsible Individual: Marchon Jackson, Associate Vice President for Research; Robert Clark, Chief Audit & Compliance Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet...
Name of Responsible Individual: Marchon Jackson, Associate Vice President for Research; Robert Clark, Chief Audit & Compliance Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications. Anticipated Completion Date: June 30, 2025
Finding 551549 (2024-008)
Significant Deficiency 2024
Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financi...
Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: Howard University uses automated processes to identify and send loan disbursement notifications to parents and students. The nightly UC4 process prompted Banner to send out a Direct Loan notification to the student and/or parent. This UC4 process showed all students who had a Direct Loan disbursement after the last nightly UC4 process was run. During a compliance review of disbursement notifications during the Fall 2023 semester and the Loans Team worked with Banner consultants to determine the reason for this. While this issue was being reviewed and a solution created, the Loans Team used the RLRDLDD report in Banner, which is a report that showed all loans disbursed. This report could be matched against the UC4 listing of loans disbursed. This check between UC4 and the RLRDLDD report was used to send out loan notifications that was missed during the UC4 process during the Fall 2023 semester. During a Spring 2024 compliance review of disbursement notifications, it was discovered the RLRDLDD report was missing disbursements as well. As a corrective action, the Loans Team then began using a loan audit report out of the Argos reporting system to identify students who may have a disbursement not included in the UC4 and/or RLRDLDD report. The support time required for maintenance of Banner was also reduced due to the ongoing integration and implementation efforts to prepare Workday for the Fall 2024 semester. This increased the length of time it took to correct the UC4 process and RLRDLDD reports. Howard no longer uses Banner to send out Graduate PLUS, Subsidized and Unsubsidized loan notifications. Workday now is now responsible for sending out the disbursement notification after a loan has disbursed and there is a record in the student’s Activity History to document the loan notification has been sent. Parent PLUS Loan notifications must be sent out manually due to Workday not having the capability to send a disbursement notification to the parent’s email on file. The “FA CR Parent PLUS Disbursement Notification Report” is run weekly out of Workday to identify all Parent Plus Loan disbursements and a notification is sent to the parent’s email address on file. Bi-semester reviews are completed by the Associate Director for Compliance to ensure the loan disbursement notifications are being sent to students and parent in the required 30-day timeline. These reviews also ensure inclusion in the loan notification of all federally required information. Anticipated Completion Date: This corrective action plan was completed during Fall 2024 implementation of Workday. Monitoring and reviewing of loan disbursements has been ongoing to ensure the Workday system is correctly identifying and transmitting Direct Loan disbursements. Given that Workday is a new ERP, Howard recognizes maintenance and review of the disbursement notification process will be ongoing.
Finding 551540 (2024-005)
Significant Deficiency 2024
Name of Responsible Individual: Keith Anderson, Associate Provost, Office of Undergraduate Studies; Paapa Berko, Federal Work-Study Coordinator; Tina Knight, Director, Center for Career & Professional Success; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Dani Hollis, Ass...
Name of Responsible Individual: Keith Anderson, Associate Provost, Office of Undergraduate Studies; Paapa Berko, Federal Work-Study Coordinator; Tina Knight, Director, Center for Career & Professional Success; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Dani Hollis, Associate Director of Operations & Customer Service; John Hooth, Senior Director of Payroll; Sasha Quinga, Senior Director, Human Resources Information Systems Corrective Action: Federal Work Study (FWS) supervisors are required to have training on the appropriate policies and procedures when hiring a FWS student. They sign off on the Federal Work Study supervisor agreement stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours, as this is a not a best practice. The Center for Career & Professional Success began using this updated FWS supervisor agreement beginning with the Spring 2025 semester. All FWS supervisors who had students for Fall 2024 were required to review and sign the updated agreement as well. The Federal Work Study Coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works. The Federal Work Study Coordinator also ensures supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. The full-time Federal Work Study Coordinator position was filled prior to the end of the Fall 2024 semester, and this ensures a full-time employee is now in place to help provide a more active review of the Federal Work Study program. One student was not paid FWS earnings within 30 days. At the time, Howard University did not print out paper checks, only providing FWS payments as a direct deposit. The student was to be paid for those two pay periods (10/8/23-10/21/23 and 10/22/23-11/4/23) on 11/3/23 and 11/17/23. The student did not have any payment selections set up in the system for the earnings to be deposited into and this delayed the receipt of the Federal Work Study payment. Working with the AVP for Enrollment Management, we have discussed with Payroll the need to process a paper check if a student chooses this delivery method. The University is also working on an awareness campaign that will encourage students to set up their direct deposit information in Workday. Students understanding the need to set up direct deposit and the willingness to process paper checks, if necessary, should prevent this finding from recurring. The Associate Director for Compliance or designee will review when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working during class hours. These reviews of FWS hours matching the students’ earnings will provide another layer of oversight. Anticipated Completion Date: The Center for Career and Professional Services hired a full-time Federal Work Study Coordinator towards the end of the Fall 2024 semester. All FWS supervisor training occurs prior to the hire of any FWS students, and the supervisor agreement has been updated as of December 2024 to reflect supervisors signing they understand students are not to have time approved prior to working those hours. The awareness campaign encouraging students to choose the direct deposit option in Workday will begin in late Spring as the Fall 2025 class prepares to enter Howard.
Finding 551538 (2024-007)
Significant Deficiency 2024
Name of Responsible Individual: Carmela Goodall, Manager, Systems and Administration (Office of the Bursar); Robin Whitfield, Associate Vice President for Finance & Bursar; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Linda Coles, Director of Cash Management, Treasury Op...
Name of Responsible Individual: Carmela Goodall, Manager, Systems and Administration (Office of the Bursar); Robin Whitfield, Associate Vice President for Finance & Bursar; Ben Carmichael, Associate Director for Compliance, Enrollment Management; Linda Coles, Director of Cash Management, Treasury Operations; Keynesha Wilson, Treasury Specialist; Kathleen Harrod, Accounts Payable Disbursement Manager; Rawle Howard, Assistant Vice President, Procurement Corrective Action: There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023. The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester. Anticipated Completion Date: Howard feels this finding has been mitigated and there will be no further findings where students received a Title IV credit balance check past the 14-day deadline. Semester or bi-semester reviews will be completed by Financial Aid to ensure the University is sufficiently meeting the federal requirements for students and/or parents to receive the Title IV credit balance check within 14 days.
View of Responsible Officials and Corrective Action Plan Air District Management concurs with the recommendation under Finding Reference Number F-2024-001. Upon review of the supporting travel expense documentation, management has found no discrepancies. Moving forward, the Air District will contin...
View of Responsible Officials and Corrective Action Plan Air District Management concurs with the recommendation under Finding Reference Number F-2024-001. Upon review of the supporting travel expense documentation, management has found no discrepancies. Moving forward, the Air District will continue to ensure that all supporting travel documentation agrees with the corresponding invoices to maintain compliance and accuracy. Regarding the overstatement of program expenditures, the Air District will initiate the recovery of the identified overcharges by deducting the amount from future reimbursement requests submitted to the Department of Homeland Security (DHS). Specifically, the Air District plans on recovering the $9,316 in overcharges from the contractor for fiscal year ending June 30, 2024. Additionally, the Air District is in the process of reviewing Fiscal Year 2025 invoices to identify any potential overcharges and will request reimbursement from the contractor, as necessary. To strengthen oversight and compliance, the Air District has begun implementing process changes as of February 2025. These changes ensure that consultant invoices align with the terms of the Air District’s contract prior to approval and payment processing. Name: Daniel Meer Title: Manager, Government Outreach & Special Projects Email: dmeer@baaqmd.gov
View Audit 352146 Questioned Costs: $1
The audit was filed late in 2023 due to an extended vacancy of a key finance position combined with the selection of a new audit firm, which resulted in additional time to prepare for and complete the audit. It is expected that this should not be an issue going forward.
The audit was filed late in 2023 due to an extended vacancy of a key finance position combined with the selection of a new audit firm, which resulted in additional time to prepare for and complete the audit. It is expected that this should not be an issue going forward.
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