Corrective Action Plans

Finding 504603 (2024-001)

None 2024

Texas College

TX

Allowable Costs / Cost Principles Questioned Costs

Finding 2024-001 – U.S. Department of Commerce (significant deficiency): We noted the following in connection with our compliance testing of time and effort reports: a) We noticed that nine (9) of 18 time and effort reports tested had incomplete and/or inaccurate percentage calculations. b) Personne...

Finding 2024-001 – U.S. Department of Commerce (significant deficiency): We noted the following in connection with our compliance testing of time and effort reports: a) We noticed that nine (9) of 18 time and effort reports tested had incomplete and/or inaccurate percentage calculations. b) Personnel Action Forms provided for six (6) of 18 time and effort reports did not specify pay allocations for employee salaries to the grant. c) The employee signature on three (3) time and effort reports provided for one (1) employee did not appear authentic. d) Three (3) time and effort reports provided for one (1) employee were not approved by a supervisor. e) One (1) time and effort report and corresponding payroll register specified salaries chargeable to a different grant but the expense was charged to the Connecting Minority Communities (CMC) grant. 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 Director of Human Resources, the Director of Sponsored Programs, and the CMC Grant PI) met to review and discuss the findings. During the meeting, staff discussed the college’s processes for completion of time and effort documents: • The Grant PI will be responsible for ensuring that the faculty and staff assigned to work on the grant have turned in a time and effort document for each month worked. o The document will be signed by the employee. o The employee will review his/her document for accuracy. o The employee will submit his/her document to appropriate person for review and signature. o The supervisor and/or Grant PI will review the time and effort document for accuracy prior to signing. o The employee and Grant PI will be responsible for keeping a signed copy of the document in their records. • The Director of Sponsored Programs will be responsible for ensuring that the Grant PI has submitted signed copies of the time and effort documents for employees working on a grant. • The Director of Sponsored Programs will also: o Review time and efforts for accuracy. If documents are inaccurate, the Director of Sponsored Programs will notify the Grant PI. The Grant PI will be responsible for ensuring that staff working on the grant make corrections to their document, sign the document, and resubmit the document for approval. o The Director of Sponsored Programs will assign the Grant PI a deadline for resubmitting corrected documents. If documents are not received by the deadline, the Director of Sponsored Programs will notify the Director of Human Resources who will adjust the employee’s salary. If the Director of Human Resources is unable to adjust the employee’s salary, he/she will make an adjusting transaction to reallocate the percentage of time that was charged to the grant, then notify the Vice President for Business and Finance. The Vice President for Business and Finance will adjust the amount of funds requested for draw or prepare a request to return drawn funds. • The Director of Human Resources will: o Confirm with the Grant PI the percentage of time each employee should be charged on a grant. o Ensure all Personnel Action forms have the correct percentages of time allocated for employees working on a grant. o Confirm with the Sponsored Program Director that all time and efforts have been submitted correctly. o Adjust the salaries of employees who are non-compliant with time and efforts. o Advise the Vice President of Business and Finance of any changes made or needed to employee’s salaries so that drawn funds can be returned or requests for draws will be adjusted. • The Vice President for Business and Finance will: o Work with Grant PI to obtain a list of all employees assigned to work on grant w/percentages of time. o Review Personnel Action forms for accuracy of time percentages provided. o Review Labor transactions for accuracy and make adjusting entries if necessary. o Return funds to awarding agency if necessary.

View Audit 327190 Questioned Costs: $1

Finding 504592 (2024-001)

None 2024

Miami University

OH

Questioned Costs Procurement, Suspension & Debarment

The Vice President for Research and Innovation will work with the Vice President for Finance and Business Services and the Director of Procurement who reports to this vice president to bring procurement practices under federal awards into compliance with the Uniform Guidance Procurement Standards 2 ...

The Vice President for Research and Innovation will work with the Vice President for Finance and Business Services and the Director of Procurement who reports to this vice president to bring procurement practices under federal awards into compliance with the Uniform Guidance Procurement Standards 2 CFR 200.300. In doing so, the following is to be undertaken: 1) Undertake review by external firm with expertise in determination of alignment of universit procurement policies and procedures to those required by Uniform Guidance. 2) Implement required elements following that review. Prior to the implementation of the recommendations by the consultant, the university's policies, which conform to the Uniform Guidance standards, will be enforced. 3) Develop and implement adequate training for impacted university employees, including, but not limited to, principal investigators, department support staff, and oversight offices (e.g., Grants & Contracts Office). 4) In conjunction with the Office of the General Counsel, the Office of Academic Personnel, and Human Resources, revise the independent contractor policies to remove the exemption that "personal services paid by external grants do not need bids regardless of the amount of payment."

View Audit 327187 Questioned Costs: $1

Finding 504591 (2024-001)

Significant Deficiency 2024

Villa Greentree, Inc. Dba Yellowwood Terrace 073-11817

CA

Questioned Costs HUD Housing Programs Procurement, Suspension & Debarment

Statement of condition 2024-001: During the year ended July 31, 2024, the Property transferred funds in excess of the surplus cash calculated at July 31, 2023. Comments on the Finding and Each Recommendation: Management should reimburse the Property's operating account in the amount of $65,142. A...

Statement of condition 2024-001: During the year ended July 31, 2024, the Property transferred funds in excess of the surplus cash calculated at July 31, 2023. Comments on the Finding and Each Recommendation: Management should reimburse the Property's operating account in the amount of $65,142. Action(s) taken or planned on the finding: Agree. On October 18, 2024, management reimbursed the Property's operating account.

View Audit 327185 Questioned Costs: $1

Finding 504569 (2024-001)

None 2024

Roger Williams University

RI

Questioned Costs Special Tests & Provisions Student Financial Aid

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement ...

Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2024 Award Year; U.S. Department of Education Criteria or Specific Requirement When a student withdraws during a term, the effective date reported to the National Student Loan Data System (“NSLDS”) for the withdrawn status is the withdrawal date used by the institution in accordance with 34 CFR 668.22 (b) or (c). In the case of the student who completes a term and does not return for the next term, leaving the course of study incomplete, the effective date is the final day of the term in which the student was last enrolled. The effective date for a completion/graduation status is the date the school assigns to the completion/graduation. (NSLDS Enrollment Reporting Guide November 20, and 34 CFR 682.610.) Condition Four students with status changes, out of seven selected for testing, had the incorrect effective date reported to NSLDS. The dates reported to NSLDS were between 6 and 26 days later than the actual effective date of the student’s status change. Views of Responsible Officials and Planned Corrective Actions The University concurs with the finding. The University intends to report the actual effective date of the student status changes. Names of Contact Person Responsible for Correction Action: Gloria Arcia, Executive Vice President for Finance and Administration and Chief Financial Officer Anticipated Completion Date: September 24, 2024

View Audit 327156

Finding 504530 (2024-001)

Significant Deficiency 2024

University of the Cumberlands, Inc.

KY

Questioned Costs Student Financial Aid Significant Deficiency

2024-001 Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University did not include the estimated amount of disbursement in the Federal Direct Loan disbursement notifications. Name of Contact Person Management ag...

2024-001 Significant Deficiency: Disbursement Notifications (U.S. Department of Education, William D. Ford Direct Loan Program, ALN #84.268) The University did not include the estimated amount of disbursement in the Federal Direct Loan disbursement notifications. Name of Contact Person Management agrees with finding 2024-001. When disbursement notifications were built for the 2023-24 award year, the calculated fields to notify students of the amount of aid being disbursed were not properly updated. Alex Campbell, Director of Financial Aid, and Kaitrin Parrett, Assistant Director of Financial Aid, are the responsible parties for the corrective action. Contact information for the responsible parties is alex.campbell@ucumberlands.edu (606) 539-5569 and kaitrin.parrett@ucumberlands.edu (606) 539-5591 Corrective Action Plan Upon identifying the deficiencies in meeting regulations for disbursement notifications, immediate corrective actions were undertaken. In collaboration with software engineers, the disbursement notification template was updated to notify students of the type of Federal Direct Loan, the date of disbursement, the amount of aid disbursed, and all other required information related to regulatory requirements. The Financial Aid Office tested and reviewed disbursement notifications for Direct Subsidized Loans, Direct Unsubsidized Loans, and Direct PLUS Loans across all student populations and confirmed that the notifications were updated and all necessary information was communicated to students before the disbursement of Fall 2024 Federal Direct Loans. In future aid years, disbursement notification templates will be internally reviewed and tested by the Director and Assistant Director of Financial Aid each semester before the disbursement of Federal Direct Loans to ensure continued compliance. Testing of the configurations for the disbursement notification template will be completed in our Student Information System’s sandbox environment. In this environment, staff will be able to simulate and disburse all Federal Direct Loans to ensure notification templates are properly set up before moving into the production tenant. Periodic reports will be generated in the production tenant to confirm that students received the appropriate disbursement notification based on their award type and disbursement date. Expected Completion Date This corrective action plan was implemented on August 1, 2024, before Fall 2024 aid disbursements began on August 30, 2024.

View Audit 327110

Finding 504522 (2024-001)

Significant Deficiency 2024

Narragansett Bay Commission

RI

Procurement, Suspension & Debarment Questioned Costs

Narragansett Bay Commission Corrective Action Plan For the Fiscal Year Ended June 30, 2024 NBC will implement procedures for all WIFIA funded contracts to ensure compliance with applicable procurement requirements. Specifically, the procedures will ensure that the applicable language related to com...

Narragansett Bay Commission Corrective Action Plan For the Fiscal Year Ended June 30, 2024 NBC will implement procedures for all WIFIA funded contracts to ensure compliance with applicable procurement requirements. Specifically, the procedures will ensure that the applicable language related to compliance with federal program requirements is included in the contracts and procurement documents. NBC will also confirm that the most current WIFIA guidance is utilized when preparing WIFIA funded contracts and procurement documents moving forward. NBC will also amend previously executed, but still active, professional service contracts to include the required contract language.Anticipated Completion Date – March 30, 2025Contact Person – David Bowen, Director of Construction and Engineering

View Audit 327088

Finding 504488 (2024-001)

Significant Deficiency 2024

North Muskegon Public Schools

MI

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Finding 2024-001: Internal Controls Over the Federal Expenditure Report Type of Finding: Control U.S. Department of Education Pass-through Entity: Michigan Department of Education Assistance Listing Number: 84.425D Award Numbers: COVID-19 213712-2021, COVID-19 213782-2223 Award Year End: Sep...

Finding 2024-001: Internal Controls Over the Federal Expenditure Report Type of Finding: Control U.S. Department of Education Pass-through Entity: Michigan Department of Education Assistance Listing Number: 84.425D Award Numbers: COVID-19 213712-2021, COVID-19 213782-2223 Award Year End: September 30, 2023 Recommendation: The School District should establish procedures to require the documented review and approval of all reports by an individual with adequate skills, knowledge, and experience prior to submission. Action Taken: The School District has implemented a new procedure requiring that all reports be reviewed and approved by a designated reviewer before submission. The reviewer, who must possess the appropriate skills, knowledge, and experience relevant to the report's content, will ensure that the information is accurate, complete, and compliant with organizational standards and regulatory requirements. Responsible Person and Anticipated Completion Date: Director of Business Services, September 2024. If the Michigan Department of Education has questions regarding this plan, please call Mark Mesbergen at (231) 719-4102.

View Audit 327050

Finding 504487 (2024-001)

Significant Deficiency 2024

Great Oaks Academy

MI

Cash Management Allowable Costs / Cost Principles Questioned Costs

Finding Number: 2024-001 Condition: The Academy did not accurately apply the approved indirect cost rate for the program at the time drawdown requests were submitted creating a cash management issue involving unallowable cost reimbursements. Planned Corrective Action: Management agrees with the find...

Finding Number: 2024-001 Condition: The Academy did not accurately apply the approved indirect cost rate for the program at the time drawdown requests were submitted creating a cash management issue involving unallowable cost reimbursements. Planned Corrective Action: Management agrees with the finding. Management identified the error after the draw down occurred and reduced the indirect costs and is in the process of enhancing procedures to prevent overdrawn amounts in the future. Contact person responsible for corrective action: Rebecca Joyner Anticipated Completion Date: 12/31/2024

View Audit 327039 Questioned Costs: $1

Finding 504486 (2024-004)

Material Weakness 2024

Ecorse Public Schools

MI

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Issue: Allowable Activities - Allocable Fringe Benefits Corrective Action Plan: The district will ensure that retirement rates are updated in the SMART program and that all accounts are charged at a consistent rate.

View Audit 327038 Questioned Costs: $1

Finding 504485 (2024-003)

Material Weakness 2024

Ecorse Public Schools

MI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Issue: Material Weakness in Internal Controls Over Financial Reporting and Material Noncompliance - Allowable Activities and Chart of Accounts and Budget Monitoring Corrective Action Plan: The district is updating and correcting all accounts in accordance with the 1022 manuals.

View Audit 327038 Questioned Costs: $1

Finding 504481 (2024-001)

Significant Deficiency 2024

College of Southern Idaho

ID

Special Tests & Provisions Questioned Costs Student Financial Aid

Finding: 2024-00 I Federal Agency Name: U.S. Department of Education Assistance Listing Number(s}: 84.007, 84.033, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely ...

Finding: 2024-00 I Federal Agency Name: U.S. Department of Education Assistance Listing Number(s}: 84.007, 84.033, 84.063, and 84.268. Program Name: Student Financial Assistance Cluster Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student's enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student's enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. During the testing of compliance for Enrollment Reporting, there was I instance out of 60 students tested where the change in student's enrollment status was not updated in NSLDS within 60 days of the effective date of the change. There was 1 instance out of 60 students tested where the enrollment status per CSI records did not agree to the enrollment status that was certified in NSLDS. Responsible Individuals: Bethany Parmer, Office of the Registrar, and Larisa Alexander, Information Technology Staff Corrective Action Plan: As a corrective measure, we have assigned a single point of contact to manage the submission of dates to the Clearinghouse, which then feeds the data to NLDS. This process was implemented last year and has proven effective, as the individual in charge has developed significant expertise and improved our reporting accuracy. However, during our transition to the new student system, we discovered that incorrect data was being fed from Jenzabar, which caused the finding. CSI will no longer input dates into both systems. The data is submitted in one system, and the systems communicate with each other, ensuring consistency and preventing discrepancies in dates. The follow chart demonstrates the flow of information for how the CAP will occur.

View Audit 327020

Finding 504472 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2010, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327004

Finding 504470 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA Ii, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327003

Finding 504468 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing Pennsylvania, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327002

Finding 504466 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing Del Ii, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327001

Finding 504464 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing De 2003, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 327000

Finding 504462 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2009, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326999

Finding 504460 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2006, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326998

Finding 504458 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2002, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326997

Finding 504456 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 2001, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326996

Finding 504454 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA 99, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326994

Finding 504452 (2024-001)

Significant Deficiency 2024

Ken-Crest Housing PA Iii, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326993

Finding 504450 (2024-001)

Significant Deficiency 2024

Kencrest Housing PA 2007, Inc.

PA

Questioned Costs Cash Management HUD Housing Programs

Although the Corporation does not currently use an interest-bearing account for project funds, we will evaluate the feasibility of using an interest-bearing account for project funds.

View Audit 326992

Finding 504416 (2024-008)

Significant Deficiency 2024

Shiloh Village School District #85

IL

Questioned Costs Allowable Costs / Cost Principles Cash Management

The District should ensure that the expenditure reports filed with the Illinois State Board of Education are reconciled with the general ledger accounts of the District prior to submission and that budgets are amended as needed. The District will take the necessary steps to reconcile the expenditure...

The District should ensure that the expenditure reports filed with the Illinois State Board of Education are reconciled with the general ledger accounts of the District prior to submission and that budgets are amended as needed. The District will take the necessary steps to reconcile the expenditure reports with the general ledger accounts before submitting to the Illinois State Board of Education and make amendments to the budget as necessary.

View Audit 326978 Questioned Costs: $1

Finding 504415 (2024-007)

Significant Deficiency 2024

Shiloh Village School District #85

IL

Procurement, Suspension & Debarment Reporting Internal Control / Segregation of Duties

The District should ensure that the expenditure reports filed with the Illinois State Board of Education are reconciled with the general ledger accounts of the District prior to submission. The District will take the necessary steps to reconcile the expenditure reports with the general ledger accoun...

The District should ensure that the expenditure reports filed with the Illinois State Board of Education are reconciled with the general ledger accounts of the District prior to submission. The District will take the necessary steps to reconcile the expenditure reports with the general ledger accounts before submitting to the Illinois State Board of Education.

View Audit 326978

Corrective Action Plans

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