Corrective Action Plans

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MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-003 Return of Title IV Funds Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing #: 84.268 Questioned ...
MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-003 Return of Title IV Funds Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing #: 84.268 Questioned Costs: None Corrective Action: We agree with the auditor’s comments, and actions stated in the recommendation. The Seminary will use the appropriate Return of Title IV Aid Worksheet found in the Federal Student Aid Handbook to ensure the calculations are accurate and percentages rounded to three decimal places. Contact Person: Michele Carr, Controller Completion Date: September 18, 2024
MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-002 Gramm-Leach-Bliley Act-Student Information Security Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance List...
MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-002 Gramm-Leach-Bliley Act-Student Information Security Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing #: 84.268 Questioned Costs: None Corrective Action: We agree with the auditor’s comments, and actions stated in the recommendation. The Seminary has updated its information security program to include the timeline for disposing of customer information securely and anticipating and evaluating changes to the information security network. Contact Person: Darnell Payne, Director of Information Technology Completion Date: September 30, 2024
MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-001 Verification Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing #: 84.268 Questioned Costs: None ...
MANAGEMENT’S CORRECTIVE ACTION PLAN CHICAGO THEOLOGICAL SEMINARY For The Year Ended June 30, 2024 Finding 2024-001 Verification Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing #: 84.268 Questioned Costs: None Corrective Action: We agree with the auditor’s comments, and actions stated in the recommendation. The Seminary will be amending its Policies and Procedures to incorporate required language to be in compliance. Furthermore, the Seminary has hired a consultant with 15 years of experience managing Federal Awards. In partnership with the consultant, the Seminary will implement additional controls to ensure application of new policies and procedures. Contact Person: Michele Carr, Controller Anticipated Completion Date: October 31, 2024
Department of Agriculture Federal Financial Assistance Listing #10.766 Communities Facilities Loans and Grants Finding Summary: There was no documented independent review of the monthly reserve fund account reconciliations as compared to the required minimum balance. Responsible Individuals: Teres...
Department of Agriculture Federal Financial Assistance Listing #10.766 Communities Facilities Loans and Grants Finding Summary: There was no documented independent review of the monthly reserve fund account reconciliations as compared to the required minimum balance. Responsible Individuals: Teresa Mallett, Chief Financial Officer Corrective Action Plan: The Board of Directors will be given an update at each board meeting with the balance in the reserve account with the required minimum balance covenant requirement. This notification will be documented in the board minutes. Anticipated Completion Date: September 24, 2024
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no d...
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The policy regarding program start dates has been changed and training has occurred to inform the community of the change in processes; data accuracy is consistently monitored by the Registrar’s Office. Name(s) of the contact person(s) responsible for corrective action: Kelsea Gonzalez Planned completion date for corrective action plan: Older program start dates for separated students have been updated with the conclusion of the corrective action plan from 2022-23, ending on 6/30/24, which overlapped with the 2023-24 audit.
View Audit 327479 Questioned Costs: $1
Federal Financial Assistance Listing #14.157 Supportive Housing for the Elderly (Section 202) Finding Summary: Due to insufficient cash flow, the Organization was unable to make the required deposit to the residual receipt reserve account in the current year. Responsible Individual: Dustin Rietsema,...
Federal Financial Assistance Listing #14.157 Supportive Housing for the Elderly (Section 202) Finding Summary: Due to insufficient cash flow, the Organization was unable to make the required deposit to the residual receipt reserve account in the current year. Responsible Individual: Dustin Rietsema, Asset Management Director Corrective Action Plan: Management has requested approval from HUD to waive the deposit requirement due to insufficient cash flow from operations. Anticipated Completion Date: October 2024
View Audit 327440 Questioned Costs: $1
Management agrees with this finding. Management is in the process of implementing a more thorough review of the claim reports to ensure proper cutoff is maintained.
Management agrees with this finding. Management is in the process of implementing a more thorough review of the claim reports to ensure proper cutoff is maintained.
View Audit 327428 Questioned Costs: $1
SEE CORRECTIVE ACTION PLAN IN AUDIT
SEE CORRECTIVE ACTION PLAN IN AUDIT
View Audit 327421 Questioned Costs: $1
SEE CORRECTIVE ACTION PLAN IN AUDIT
SEE CORRECTIVE ACTION PLAN IN AUDIT
View Audit 327421 Questioned Costs: $1
SEE CORRECTIVE ACTION PLAN IN AUDIT
SEE CORRECTIVE ACTION PLAN IN AUDIT
View Audit 327421 Questioned Costs: $1
Finding Number: 2024-002 Condition: Through an internal audit review, the University identified costs charged to this program that were determined to be unallowable or questionable. Planned Corrective Action: The university’s Internal Audit department identified the noncompliance referenced in th...
Finding Number: 2024-002 Condition: Through an internal audit review, the University identified costs charged to this program that were determined to be unallowable or questionable. Planned Corrective Action: The university’s Internal Audit department identified the noncompliance referenced in this finding. The university promptly informed the sponsor and provided refunds for the inappropriate charges. Staff involved in these improper actions were disciplined up to and including termination. Current staff have been counseled and provided additional training. The University has also instituted an additional review step for all large dollar projects and provides central support for the administration of large grants as needed. Contact person responsible for corrective action: Patrick Clark Anticipated Completion Date: N/A, as actions to correct this issue were taken prior to this audit
View Audit 327409 Questioned Costs: $1
Finding Number: 2024-001 Condition: The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the close...
Finding Number: 2024-001 Condition: The University did not complete full grant closeout procedures in a timely manner for 10 out of 25 grants that were tested with a period of performance that ended in the year ended June 30, 2024. For 2 of those 10, there was not an independent review of the closeout checklist performed. Planned Corrective Action: SRS Accounting works closely with the departments on grant closeouts. Although a checklist was not signed by a supervisor, many of these awards had departmental agreement of final expenses. In two cases, the award was fully spent. System restrictions prevent spending 90 days after the grant end date. Due to department and system controls, no unallowable costs were reported on any award. SRS accounting will provide further award closeout training to its team members. Additionally, SRS Accounting added a supervisory team member, which will help mitigate this situation going forward. Contact person responsible for corrective action: John Ungruhe Anticipated Completion Date: 03/01/2025
Documentation of Reconciliations Recommendation: We recommend the University explore options to make the year-to-date reconciliations and documentation of student Pell and Direct Loans more efficient. Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Co...
Documentation of Reconciliations Recommendation: We recommend the University explore options to make the year-to-date reconciliations and documentation of student Pell and Direct Loans more efficient. Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting have provided in-house training to all pertinent financial aid staff on monthly reconciliation procedures. Progress has been made importing the monthly Pell SAS file to WBU’s financial aid system, PowerFAIDS. Work will continue on importing the Direct Loan SAS file into PowerFAIDS. Person Responsible for Corrective Action Plan: Robert Hamilton, Executive Director of Financial Aid and Brooke Tyler, Assistant Director of Compliance & Reporting Anticipated Date of Completion: December 15, 2024.
Gramm-Leach-Bliley Act (GLBA) Compliance Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year. Planned Corrective Action: Wayland Baptist University will implem...
Gramm-Leach-Bliley Act (GLBA) Compliance Recommendation: We recommend the University allocate sufficient resources to address all updated requirements of GLBA. We commend the University for the work completed on GLBA in the past year. Planned Corrective Action: Wayland Baptist University will implement multi-factor authentication (MFA) in alignment with Center for Internet Security (CIS) Control 6 for all externally exposed applications, including PowerFAIDS NetPartner. We will mitigate risk for internal-only applications by enabling MFA where available and authorizing access to vulnerable applications only from our Single Sign On (SSO) and MFA portals when available. For systems where MFA cannot be enabled, the University will implement a process to document the exception with a plan to bring the system into compliance. The University will review current policies related to data deletion and make necessary changes to the policy to adhere to updated GLBA requirements. Person Responsible for Corrective Action Plan: Cagan Cummings, Chief Information Officer Anticipated Date of Completion: June 20, 2025
Incorrect Pell Calculations Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will continue to provide in-house training...
Incorrect Pell Calculations Recommendation: We recommend a process be used to adjust Pell to be paid in alignment with enrollment status. Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will continue to provide in-house training to all financial aid staff to ensure proper understanding of Pell calculations. Each Summer session, the Office of Financial Aid will request weekly Summer enrollment reports to audit students for Summer Pell Grant eligibility. Person Responsible for Corrective Action Plan: Robert Hamilton, Executive Director of Financial Aid and Brooke Tyler, Assistant Director of Compliance & Reporting Anticipated Date of Completion: May 31, 2025
View Audit 327385 Questioned Costs: $1
2024-002 Return of Title IV (R2T4) Calculations Recommendation: We recommend the University continue to provide additional training for counselors performing R2T4 calculations. Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting wil...
2024-002 Return of Title IV (R2T4) Calculations Recommendation: We recommend the University continue to provide additional training for counselors performing R2T4 calculations. Planned Corrective Action: The Executive Director of Financial Aid and the Assistant Director of Compliance & Reporting will provide regular in-house R2T4 training specific to WBU for all financial aid staff. All financial aid staff responsible for R2T4 will be required to complete pertinent training provided by FSA and purchased through NASFAA. Person Responsible for Corrective Action Plan: Robert Hamilton, Executive Director of Financial Aid and Brooke Tyler, Assistant Director of Compliance & Reporting Anticipated Date of Completion: December 15, 2024.
Title: Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Explanation of disagreement wi...
Title: Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend reviewing the components of the enrollment roster file to ensure the correct effective date is reported correctly for both the "Campus Level" and "Program Level". Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have confirmed that both Undergraduate and Graduate processes for enrollment reporting are aligned, we reviewed the processes, and provided updated training to all employees who enter dates in our record-keeping system. We have a plan in place to provide updated and timely training for any new employees responsible for NSLDS reporting data. Name(s) of the contact person(s) responsible for corrective action: Dwight R Berreth Planned completion date for corrective action plan. August 1, 2024
Recommendation: The cost of additional personnel to properly segregate accounting and financial responsibilities would appear to outweigh the benefits received. However, management and the Board of Education should constantly be aware of the possibility that errors or fraud could occur and contin...
Recommendation: The cost of additional personnel to properly segregate accounting and financial responsibilities would appear to outweigh the benefits received. However, management and the Board of Education should constantly be aware of the possibility that errors or fraud could occur and continue current practices mitigating these possibilities and examine and implement other mitigating controls when appropriate. Action Taken: The District has assessed the benefits and costs associated with proper segregation of duties for the District and has determined that costs would outweigh benefits received. The District understands the inherent risks associated with improper segregation of accounting functions. Management has communicated the need for transactions to be well supported by documentation as well as seeking appropriate authorization when appropriate. The District requires monthly reporting to the Board of Education for all disbursements to ensure transactions are proper and potential errors and irregularities are identified on a timely basis. The District will continue to review accounting procedures and processes to further mitigate this internal control deficiency whenever possible and feasible.
Action taken in response to finding: The employee responsible for eligibility processing and verification is new to the process. The employee attended all of the trainings provided by CDE prior to conducting verification. The employee misinterpreted “net wages” vs “gross wages” on the paystub, whi...
Action taken in response to finding: The employee responsible for eligibility processing and verification is new to the process. The employee attended all of the trainings provided by CDE prior to conducting verification. The employee misinterpreted “net wages” vs “gross wages” on the paystub, which led to this discrepancy. The household had listed net wages on their application this year and prior years. The student’s status was corrected and backdated to the verification response date. April and May 2024 claims are not affected by overpayment due to the student’s status having been updated before claims were sent to the state for payment. USDA disregards overpayment of reimbursement if the amount does not exceed $600 annually (Section 119c). Since the amount is not over $600, CDE is not required to collect the discrepancy. The District will move into 100% Community Eligibility Provision (CEP) for SY 2024-2025, and continuing for up to 5 consecutive years following enrollment into the provisional program. CEP does not require income application submittal, thus does not host an annual verification certification because data is received solely through Direct Certification reports provided by CDE monthly. Staff responsible for eligibility determination will continue to take the online trainings from CDE and our Nutrition Software annually as required. Name(s) of the contact person(s) responsible for corrective action: Kari Jacobs Planned completion date for corrective action plan: 5/2/2024
View Audit 327327 Questioned Costs: $1
Finding 504695 (2024-003)
Significant Deficiency 2024
Significant Deficiency in Internal Control over Compliance (Suspension and Debarment) Recommendation: We recommend the Village carefully review federal suspension and debarment requirements for proper documentation needed. The Village should consider use of a Federal procurement checklist. Explana...
Significant Deficiency in Internal Control over Compliance (Suspension and Debarment) Recommendation: We recommend the Village carefully review federal suspension and debarment requirements for proper documentation needed. The Village should consider use of a Federal procurement checklist. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Village has developed a review process which satisfies the requirements for suspension and debarment per the Uniform Guidance. Staff is assigned to monitoring the need for this process and when appropriate, complete necessary procedure to document findings relative to suspension or debarment. Name of the contact person responsible for corrective action: Angela Schultz, Comptroller Planned completion date for corrective action plan: April 30, 2025
MANAGEMENT RESPONSE AND CORRECTIVE ACTION PLAN U.S. Department of Education Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FE...
MANAGEMENT RESPONSE AND CORRECTIVE ACTION PLAN U.S. Department of Education Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2024-01: Special Tests and Provisions – NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of the enrollment status reporting, we noted that the incorrect enrollment status and effective date was included in NSLDS. Recommendation: The institution should evaluate their procedures and policies related to reporting status changes and effective dates to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college has reviewed and updated procedures to ensure that graduation and enrollment files are submitted in the necessary sequence to reflect the appropriate enrollment status and effective dates. Name(s) of the contact person(s) responsible for corrective action: Nanci A. Beier, Registrar Planned completion date for corrective action plan: Completed
October 31, 2024 Corrective Action Plan To whom it may concern: This letter includes the corrective action plan in response to the audit finding from the Single Audit for the 2023-2024 award year. Audit Finding 2024-001: For students who did not return from an approved leave of absence or tho...
October 31, 2024 Corrective Action Plan To whom it may concern: This letter includes the corrective action plan in response to the audit finding from the Single Audit for the 2023-2024 award year. Audit Finding 2024-001: For students who did not return from an approved leave of absence or those that took a leave of absence that did not meet the requirements of an approved leave of absence, predominantly being leaves of absences in excess of 180 days in any 12-month period, Art Center did not consistently report to the NSLDS the effective date of the withdrawal as the date the student began the leave of absence. Management Response: ArtCenter management acknowledges that some incorrect Enrollment Reporting data were transmitted through the National Student Clearinghouse (“NSC”) to the National Student Loan Data System (“NSLDS”). However, this error was not due to any insufficiencies in ArtCenter’s policies, but rather, was due to a technical misunderstanding regarding which data fields are extracted from Colleague for NSC reporting. More specifically, if a student takes a second Leave of Absence (“LOA”), it had been ArtCenter’s practice to record the student’s actual last date of attendance in the “Last Date of Attendance” field on the Student Hiatus Summary screen in Colleague, but the file that NSC requires schools to use to extract reporting data does not pull data from this field, and as a result, the resulting reported information was inaccurate. Corrective Action Plan: To remediate this finding and avoid future inaccuracies in Enrollment Reporting, we have adjusted our procedures to ensure the appropriate withdrawal date is submitted to NSC for transmission to NSLDS, in alignment with NSLDS Enrollment Reporting definitions and expectations. Please let us know if you have any additional questions. Sincerely, Kaitlin Wallace Executive Director, Financial Aid Art Center College of Design 1700 Lida St. Pasadena, CA 91103 626.396.2214
Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The reason that R214 were done late/inaccurately was due to an employee who was new to the position and instead of seeking assistance in a timely manner, waited until the prior retired Director of Student accounts was...
Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: The reason that R214 were done late/inaccurately was due to an employee who was new to the position and instead of seeking assistance in a timely manner, waited until the prior retired Director of Student accounts was contracted in to assist. This employee was transferred from enrollment department oversight and then transferred to business office oversight mid-year. Neither department could provide the necessary management of this position and that is when they reached out to contract back the former Director of Student Accounts. Our only other trained R2T4 employee left LPU in Spring 24 and due to staffing challenges with FAFSA Simplification, we could not get someone new trained in time. We have been working with a consulting firm, JM Solutions, and with consultants' input, we are restructuring the financial aid and Student Accounts department to fall under one direct oversight. LPU created an Associate Vice President of Enrollment Services who oversees FinancialAid, Student Accounts and Registrar. Underthe Associate VP, there is a new Director of Student FinancialServices (this combined role is the Director of Financial aid and Student Accounts). Going forward R2T4 will be done on the COD system per consultants' recommendation. Currently the Director of Student Financial Services is being trained on R2T4, and they are seeking to hire a fulltime position of a Financial Aid processor who will be trained on R2T4 as well. For now, the Associate VP and Director of Student Financial Services will be working together to ensure R2T4 are completed according to regulations, with additional oversight by consultants throughout the academic year. Person Responsible for Corrective Action Plan: Amber Burnett, Associate Vice President of Enrollment Services and Angel Cavazos, Director of Student Financial Services Anticipated Date of Completion: At this time oversight and changes are in place for the R2T4 process
Charlton Heston Academy respectfully submits the following corrective action plan for the year ended June 30, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2024 Academy Contact Person: Frank Patterson, Chief Financial Officer F...
Charlton Heston Academy respectfully submits the following corrective action plan for the year ended June 30, 2024. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period Year ended June 30, 2024 Academy Contact Person: Frank Patterson, Chief Financial Officer Finding 2024-001 – Significant deficiency Recommendation: We recommend the Academy establish improved controls for preparing and reviewing year-end reconciliations. The Academy should ensure that reconciliations are completed in a timely manner and agree to the general ledger. Actions to be taken: The Academy concurs with the facts of this finding and are in the process of adding human capital/capacity, developing a revised formal timeline, and checklist of year-end procedures as recommended. Finding 2024-002 – Significant deficiency Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented procedures to prevent this in the future.
Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. (a) The College had a difference in the F...
Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. (a) The College had a difference in the Federal Work-Study program, which was not reconciled to the general ledger. (b) One (1) out of sixty (60) students tested for verification was missing their parent’s tax return. Total questioned cost was $3,698. Auditor’s Recommendation – The College should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action – The College accepts the auditor’s recommendations. Following the receipt of the recommendation, College staff (the VP for Business and Finance, the VP for Student Affairs, and staff from the Financial Aid Office) were informed of the findings. Staff noted the unwillingness of a student to provide parent’s tax document for verification, which lead to audit finding. Business Office and Financial Aid staff were advised to review the reported variance with the Federal Work-Study program; the College will have the FWS variance reconciled prior to the physical “closing of its books”. The College has a process that it uses to reconcile accounts and has no immediate plans to change the process. Staff are reminded of the process; the VP for Business and Finance will become more active in reviewing reconciliations for accuracy.
View Audit 327190 Questioned Costs: $1
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