Corrective Action Plans

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Ineligible Programs Planned Corrective Action: Additional training regarding program eligibility has been conducted with the Processing Team. Previously unknown functionality to designate a program as being ineligible for Title IV aid in the Colleague administrative system was identified and implem...
Ineligible Programs Planned Corrective Action: Additional training regarding program eligibility has been conducted with the Processing Team. Previously unknown functionality to designate a program as being ineligible for Title IV aid in the Colleague administrative system was identified and implemented. Title IV funds can no longer be disbursed for programs marked as ineligible. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: February 2024
View Audit 299440 Questioned Costs: $1
Higher Education Emergency Relief Fund (HEERF) Earmarking Planned Corrective Action: Funds are to be returned. Person Responsible for Corrective Action Plan: Gary E Estes, Director of Accounting Anticipated Date of Completion: June 2024
Higher Education Emergency Relief Fund (HEERF) Earmarking Planned Corrective Action: Funds are to be returned. Person Responsible for Corrective Action Plan: Gary E Estes, Director of Accounting Anticipated Date of Completion: June 2024
View Audit 299440 Questioned Costs: $1
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: The university outsourced the R2T4 calculation process in October 2022 to provide timely processing of returns. Additionally, to reduce the overall amount of withdrawal calculations, the university moved from an Ins...
Inaccurate and Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: The university outsourced the R2T4 calculation process in October 2022 to provide timely processing of returns. Additionally, to reduce the overall amount of withdrawal calculations, the university moved from an Institution Required to Take Attendance to an Institution Not Required to Attendance in May 2023. Additional reports were created to accommodate this change and identify withdrawals. Staff attended the NASFAA R2T4 training course. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of SFS Processing Anticipated Date of Completion: November 2023
Lack of Administrative Capability Planned Corrective Action: The university added and filled vacant positions in the financial aid office which provided additional capacity for processing and compliance. New levels of oversight and accountability were established and are being followed. Previously ...
Lack of Administrative Capability Planned Corrective Action: The university added and filled vacant positions in the financial aid office which provided additional capacity for processing and compliance. New levels of oversight and accountability were established and are being followed. Previously unknown functionality in the Colleague system was identified and implemented preventing the awarding of aid to ineligible programs. Person Responsible for Corrective Action Plan: David Richards, Director of Student Financial Services Anticipated Date of Completion: February 2024
Corrective Action Plan to Audit Finding #2023-001: It was determined at the end of the 2022-2023 school year that $176,938 of indirect costs were charged to the Education Stabilization Fund in error. Prior to the start of the 2022-2023 school year, we were informed that the guidelines changed for s...
Corrective Action Plan to Audit Finding #2023-001: It was determined at the end of the 2022-2023 school year that $176,938 of indirect costs were charged to the Education Stabilization Fund in error. Prior to the start of the 2022-2023 school year, we were informed that the guidelines changed for some funding sources regarding indirect costs. We will be correcting the action as instructed in our books and will implement an annual review process for funding sources to ensure that we are able to implement all guidelines Sincerely, Denise R. Jaramillo, Ed. D. Superintendent
View Audit 299438 Questioned Costs: $1
Finding 2023-004 Procurement and Suspension and Debarment – Internal Control and Compliance over Suspension and Debarment City will incorporate the Uniform Guidance requirements into its existing grant policies and procedures to ensure the City is in compliance with the Uniform Guidance. City staff...
Finding 2023-004 Procurement and Suspension and Debarment – Internal Control and Compliance over Suspension and Debarment City will incorporate the Uniform Guidance requirements into its existing grant policies and procedures to ensure the City is in compliance with the Uniform Guidance. City staff will access SAM.Gov to check for possible party ineligibility following receipts of an offer or proposal and again, immediately before making the award. For every CIP project that is advertised for bids, the Engineering Division’s is currently preparing a detailed analysis of the bid amounts received that includes a check of the low-bid contractor’s license, insurance, and references prior to the award of contract. In addition, staff verifies that neither the contractor nor any of its key personnel appear on the Federal or State debarment lists. All of this documentation is then typically compiled in the project file in both hardcopy and electronically. However, to ensure consistency that all pre- and post-construction documentation is properly filed for each project, staff will utilize a project checklist modeled after Caltrans’ “Exhibit 19 - Construction Review Checklist” from its Local Assistance Program Manual as applicable. Responsible Person: Director of Public Works Expected Implementation Date: July 1, 2024
Finding 387142 (2023-005)
Significant Deficiency 2023
Fiscal Operations and Application to Participate (FISAP) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their procedures to implement a review process in place befo...
Fiscal Operations and Application to Participate (FISAP) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their procedures to implement a review process in place before the FISAP is submitted to the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure that procedures are in place to ensure the FISAP data has a review by a second person prior to submission. The hiring of the Director of Financial Aid will greatly assist in ensuring accuracy of reporting. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: September 2024 filing.
Finding 387136 (2023-004)
Significant Deficiency 2023
Gramm-Leach-Bliley Act Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the requ...
Gramm-Leach-Bliley Act Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review their documentation and ensure that the written information security program includes the required elements. We also recommend reviewing the changes in the Gramm-Leach-Bliley Act regulations that were required to be implemented as of June 9, 2023. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College appointed an Information Technology Point of Contact in 2023. Tabor College contracted with Tenfold Security to assist with the requirements of the Gramm-Leach-Bliley Act (GLBA). A Risk Assessment was performed in April 2023 and the final report issued in May 2023. Penetration testing has been completed on a regular basis beginning March 27, 2023. Multi-factor Authentication (MFA) implementation began in June with full implementation with the return of students in August 2024. MFA has been fully implemented for all employees, students, and Board members. The significant undertaking of establishing required Policies and Procedures began in June 2023. A GLBA Committee has been recently been formed to help ensure compliance with all of the established policies and procedures. Tabor continues to work with Tenfold to ensure compliance with the GLBA requirements as of June 9, 2023. Name(s) of the contact person(s) responsible for corrective action: Cathy Castle, Vice President for Business and Finance Planned completion date for corrective action plan: 2024 and ongoing. If the Department of Education has questions regarding this plan, please call Cathy Castle at 620-947-3121 x 1056.
Finding 387130 (2023-003)
Significant Deficiency 2023
National Student Loan Data System (NSLDS) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately re...
National Student Loan Data System (NSLDS) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses 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: Tabor College utilizes a clearing house for submitting student statuses. Enrollment is submitted on a monthly basis, at the beginning of the term, each month and then when the term has ended. Graduate students are reported at the end of the term. Tabor will ensure that all students statuses are filed accurately and timely. A Director of Financial Aid has been hired. This position had been filled by an interim person. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: April 2024
Finding 387124 (2023-002)
Significant Deficiency 2023
Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure...
Eligibility and Certification Approval Report (ECAR) Award Period: July 1, 2022 to June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Tabor College will ensure that ECAR is updated in a timely manner when there is a change in a position of an official for the institution. The two third-party collection agencies for Perkins were added to ECAR on October 31, 2023. Name(s) of the contact person(s) responsible for corrective action: Erica Clark, Director of Financial Aid Planned completion date for corrective action plan: March, 2024
2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...
2023-003 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: We examined 40 student files and we noted 3 out of 40 students were not properly awarded Direct Loans. One of these students was improperly awarded subsidized loans and instead should have received unsubsidized loans. Additionally, the College did not report actual loan disbursement dates to the Common Origination and Disbursement (COD) system for 1 of the 40 students in the sample (2.5%). We consider these conditions to be instances of noncompliance in internal control over compliance relating to the Eligibility compliance requirement. Management Response: Cost of Attendance (COA) calculations were not updated to ensure ratio of subsidized versus unsubsidized loans were correct. It looks like awards were not being recalculated as additional need based aid was added to awards for these students. Corrective Action Plan: New financial aid software (JFA) was implemented for the 2023-2024 academic year. A component of this software is a compliance check for COA and other issues. The compliance check for over awards should catch instances of the wrong sub/unsub ratio in the future. Responsible Person: Tim Marten, Director of Financial Aid Implementation Date: Fall 2023
View Audit 299424 Questioned Costs: $1
Finding 387115 (2023-001)
Significant Deficiency 2023
2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...
2023-001 – Student Financial Aid Cluster – (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 – Year Ended June 30, 2023 Condition: During our testing of forty individuals receiving federal work study, we noted 26 individuals (65%) that had timecards for hours worked that were not approved by a supervisor. We consider this condition to be a significant deficiency relating to the Activities Allowed or Unallowed compliance requirement. Management response: Timecard approval was completed by email notification. During 2022/23, a new email system was installed, and many emails related to timecards were lost. Corrective Action Plan: Starting in August 2023 all timecard approvals were documented in the payroll system (Paycor). HR prior to processing payroll requires all timecards be system documented as approved. Responsible Person: Kathleen Hermacinski, Human Resources Coordinator Implementation Date: August 2023
View Audit 299424 Questioned Costs: $1
2023-002 Eligibility Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 ...
2023-002 Eligibility Federal Agency: Student Financial Assistance Cluster - U.S. Department of Education Program Titles and ALN: Federal Pell Grant Program (ALN 84.063) and Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers: E-P063P130272 (7/1/2022 - 6/30/2023), P268K130272 (7/1/2022 - 6/30/2023) Contact Person: Jean McDonald Rash, AVP Enrollment Services, 848-932-2605 Corrective Action: In order to correct the issue of students being awarded in excess of their cost of attendance, a weekly report has been developed to capture any student whose financial aid, from any source, exceeds the assigned cost of attendance. The Financial Aid Processing team in University Enrollment Services receives and resolves the issues in the report weekly to ensure that students are not awarded in excess of their assigned cost of attendance. In order to correct the issue of the incorrect calculation of the cost of attendance components, a testing plan has been developed that includes manually checking each program cost of attendance prior to signing off for production aid packaging. The script that caused the cost of attendance components to be doubled was corrected prior to the 2023-2024 aid year. Anticipated Completion Date: Completed
View Audit 299417 Questioned Costs: $1
CContact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – December 29, 2023
CContact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures to ensure all students who receive a free or reduced meal have a current and accurate application on file. Completion Date – December 29, 2023
Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures for verifying free and reduced applications. Completion Date – December 29, 2023
Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District will implement policies and procedures for verifying free and reduced applications. Completion Date – December 29, 2023
Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District has implemented new meal count procedures effective May 2023. Completion Date – May 1, 2023
Contact Person – Thomas A. Jerome, Superintendent Corrective Action Plan – The District has implemented new meal count procedures effective May 2023. Completion Date – May 1, 2023
2023-007 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ...
2023-007 Allocation of Grant Expenses U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that all expenses are for actual expenses incurred, and that timely reconciliations are performed to ensure the expenses are properly charged to the correct assistance listing number and grant. Action Taken: The Board has developed a process to correctly allocate expenditures to the correct funding stream. At each month’s end, all employees complete an allocation spreadsheet. When all spreadsheets are completed, approved, and turned in, the Board determines the allocation of payroll and expenditures. Expenditures that occurred in March will be allocated using the allocation chart for February. Also, this procedure is backup for each cash request that is submitted for funding. And, this is reviewed for the reconciliation between the cash request and the Board’s accounting software.
2023-006 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities particip...
2023-006 Eligibility U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement policies and procedures to ensure that the necessary controls are in place to properly verify the eligibility of all Youth and Adult Activities participants. Action Taken: The Board’s Youth Liaison monitors the In School and Out of School Youth eligibility every six months following the policy and procedures referencing the CF200. The Board’s Youth Liaison reviews the Youth files to determine if the Youth meets the eligibility criteria for the Youth program. Her monitoring is reviewed every six months during the State Audit. The Board will review her monitoring along with copies of the completed registrations from the Board’s subrecipient which determines which program the youth (Youth In or Youth Out) is eligible for the fiscal year. The Board will state that they have reviewed the eligibility perimeters and these were followed by the subrecipient and verified by the Youth Liaison. For the Adult Program, the Board has implemented internal controls to ensure each applicant completes the applications and to determine if they are eligible for the programs the Board offers. Our Business Services Manager reviews each application taken by the Board’s Career Services Coordinator and ensures they are in the correct program by the application.
2023-004 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal cont...
2023-004 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board added an internal control for the sake of reporting, for reports that are submitted to Workforce WV. Reports will be reviewed and approved by one of the managers of the Board within the time the report is due. For the ETA-9130 Financial report, the Board cannot submit this report since the Board is not a grantee for a Federal organization. Workforce WV submits this report by gathering the information they receive from all Development Boards and consolidates in this report for the Department of Labor. To send Workforce WV the reports they need to file this report, the Board will have the reports prepared and not submit them until another of the Board’s managers has reviewed and approved the preparation and submission of these reports in a timely manner.
2023-003 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will c...
2023-003 Earmarking U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement controls and procedures to ensure that all requirements for earmarking within the Uniform Guidance are properly followed. Action Taken: The Board will create a spreadsheet that shows the earmarking percentage for each category. The Board will review various reports for each funding stream at month end and record the actual earmarking percentage for each month. With this information, the Board will discuss these percentages at the monthly manager’s meeting, budget meeting and Board of Directors meeting. If a plan of action is needed, a plan of action will be developed. Also, Workforce WV has a software system that takes the expenditures reported for each funding stream, for each month, called the MACC report in which each Region completes a report that will verify which percentages are not in compliance. The Board will be comparing this report to the analysis report from the State.
Finding 387003 (2023-004)
Significant Deficiency 2023
Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...
Finding 2023-004 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that exit interviews are completed with students in a timely fashion. There was also a transition in leadership during this time. The new leader did not realize the exits were being sent manually. The system has since been configured to send out exits upon graduation and an exit is triggered for when the student graduates, withdraws or drops to less than half-time.
Finding 386999 (2023-002)
Significant Deficiency 2023
Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...
Finding 2023-002 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure that changes in students enrollment status that trigger a return of title IV funds are completed within the required 45 day time period. During the transition of systems the report used to look at students who might need to be a withdrawal and have a R2T4 calculation performed needed to be rebuilt for the new system. During this process the report did not always work correctly. Those flaws have been fixed the report is being worked on a weekly basis.
Finding 386998 (2023-001)
Significant Deficiency 2023
Finding 2023-001 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-...
Finding 2023-001 Personnel Responsible for Corrective Action: Senior Vice President, Student Experience – Joseph Sallustio Anticipated Completion Date: March 2024 Corrective Action Plan: The University has completed its implementation of Anthology, a student information system, during the 2023-2024 fiscal year. The new system has several built in features that are supplemented with internal controls to ensure financial aid is awarded correctly. The system automatically awards the student at full-time, the awards are then confirmed through a review process before sending out the award notification, and again before payment. The system compares the full-time award status with the actual enrollment and if they do not match the student will fail for payment and we will revise the award.
Finding 386997 (2023-001)
Significant Deficiency 2023
The City will update policies and procedures over reporting, including additional independent reviews to ensure accurate completion.
The City will update policies and procedures over reporting, including additional independent reviews to ensure accurate completion.
Boone-Apache Public Schools will develop internal control policies and procedures to meet the requirements and procedures of the Davis-Bacon Act. The updated policies and procedures will assure that the district is in compliance with contracts, including inserting the prevailing wage clauses and en...
Boone-Apache Public Schools will develop internal control policies and procedures to meet the requirements and procedures of the Davis-Bacon Act. The updated policies and procedures will assure that the district is in compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an affective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. The updated policies and procedures will ensure that all items are posted at the work site to ensure compliance. The internal control policies and procedures will be completed on March 12, 2024.
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