Corrective Action Plans

Finding 372675 (2023-004)

Significant Deficiency 2023

MA

Student Financial Aid Questioned Costs Matching / Level of Effort / Earmarking

Management concurs with the recommendation. Going forward, there will be at least two reviews of the FISAP prior to the annual filing, including all updates, to better ensure complete and accurate completion prior to filing with the U.S. Department of Education.

View Audit 293797

Finding 372674 (2023-003)

Significant Deficiency 2023

Berklee College of Music, Inc.

MA

Internal Control / Segregation of Duties Questioned Costs Allowable Costs / Cost Principles

Management concurs with the recommendations provided. Berklee will enhance its protocols to ensure adequate support is in place to document that reports are prepared and reviewed by appropriate individuals, that duties are appropriately segregated between preparer and review, and that reports are ac...

Management concurs with the recommendations provided. Berklee will enhance its protocols to ensure adequate support is in place to document that reports are prepared and reviewed by appropriate individuals, that duties are appropriately segregated between preparer and review, and that reports are accurately prepared and reviewed prior to posting with the U.S. Department of Education.

View Audit 293797

Finding 372664 (2023-002)

None 2023

Bulter County Community College

KS

Questioned Costs Reporting

Criteria or Specific Requirement – Under the CARES Act 18004(e) and the CRRSAA 314(e), there are three components to reporting HEERF, public reporting on student aid portion, public reporting on the institutional portion, and annual reporting. The public reporting on student aid requires institution...

Criteria or Specific Requirement – Under the CARES Act 18004(e) and the CRRSAA 314(e), there are three components to reporting HEERF, public reporting on student aid portion, public reporting on the institutional portion, and annual reporting. The public reporting on student aid requires institutions to publicly post certain information, including four items defined by the U.S. Department of Education (ED) as key items, on their website as soon as possible but no later than 30 days after the publication of the notice or 30 days after the ED first obligated funds. The report must be updated no later than 10 days after the end of each calendar quarter. The public reporting on institutional aid requires institutions to publicly post the HEERF institutional reporting form on the institution's primary website no later than 10 days after the end of each calendar quarter with the exception of the first report, which was due October 30, 2020, and the report covering the first quarter of 2021, which was due July 10, 2021. Recommendation – We recommend that management review this area and establish procedures to ensure required reports are completed timely. Views of Responsible Officials and Corrective Action Plan – Management concurs with the findings and recommendation. Responsible personnel will review current guidance available from the Department of Education website and develop internal procedures to ensure timely compliance. This plan will include personnel (responsibility) redundancy to account for employee absences or turnover, and a monthly review of available guidance to ensure the College stays current with any changes to this guidance. Individuals Responsible – Kerry Potter, Director of Accounting Anticipated Completion Date – February 27, 2024

View Audit 293755

Finding 372656 (2023-001)

Significant Deficiency 2023

Buena Park Elementary School District

CA

Questioned Costs Allowable Costs / Cost Principles

Audit Finding 2023-01: Education Stabilization Funds - Indirect Costs Action Plan: In addition to the procedure of verifying Indirect cost eligibility during budget development for a new grant, the District will implement an additional review process to verify the validity of charging Indirect Cost ...

Audit Finding 2023-01: Education Stabilization Funds - Indirect Costs Action Plan: In addition to the procedure of verifying Indirect cost eligibility during budget development for a new grant, the District will implement an additional review process to verify the validity of charging Indirect Cost at the end of each fiscal year. The Director Fiscal Services will review relevant grant agreements and relevant federal guidance as a part of the year-end closing process to determine if indirect costs may be charged and what rate may be used. This plan is approved and submitted by the Chief Financial Officer, Sandra Poteet.

View Audit 293740 Questioned Costs: $1

Finding 372650 (2023-001)

Significant Deficiency 2023

Pendergast Elementary School District No. 92

AZ

Questioned Costs Cash Management Reporting

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Krystal Burnham, Food Service Compliance Coordinator/ Danny Robbins, Interim Director of ...

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Krystal Burnham, Food Service Compliance Coordinator/ Danny Robbins, Interim Director of Budget and Finance Anticipated Completion Date: July 31, 2023 Planned Corrective Action: The District will ensure that monthly counts are supported by documentation and verified by a second staff member and agree to the accuracy of the reimbursement claims prior to submission to the Arizona Department of Education. The District will also ensure that reimbursement claims are submitted within the required time period after month end and any identified issues with measures that prevent their recurrence.

View Audit 293730

Finding 372578 (2023-001)

Material Weakness 2023

Lutheran Housing Corporation at Middletown, Inc.

MA

Questioned Costs HUD Housing Programs Material Weakness

Audit period: July 1, 2022 – June 30, 2023The 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—FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS2023-001 Section 202 Supportive Housi...

Audit period: July 1, 2022 – June 30, 2023The 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—FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS2023-001 Section 202 Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: The auditor recommends that the Organization review the HUD Management Agent Handbook and revise its internal control policies with regards to calculating its allowable management fee per the Handbook. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is reviewing its current training regarding the calculation of allowable management per the Handbook. While budgeted revenue will remain as the basis for the calculation, a process will be put in place to review amounts charged against allowed % of collected revenues each year. Management will review the calculation and a Receivable or Payable will be recorded to “true up” the amount to actual for the Fiscal Year. Name(s) of the contact person(s) responsible for corrective action: Sergio Plaza Planned completion date for corrective action plan: December 15, 2023 and Ongoing If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Sergio Plaza at 508-688-5608.

View Audit 293658

Finding 372577 (2023-001)

Material Weakness 2023

Ascentria Community Services, Inc.

MA

Questioned Costs Material Weakness Reporting

U.S. Department of Health and Human Services 2023-001 Refugee and Entrant Assistance Discretionary Grants – Assistance Listing No. 93.576 Recommendation: It is recommended that the Organization design controls to ensure time and effort spent on programs are properly documented in accordance with U...

U.S. Department of Health and Human Services 2023-001 Refugee and Entrant Assistance Discretionary Grants – Assistance Listing No. 93.576 Recommendation: It is recommended that the Organization design controls to ensure time and effort spent on programs are properly documented in accordance with Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ascentria will be implementing procedures in accordance with 2 CFR 200.430(i) by collecting effort reports for exempt employees who are split across multiple federally funded contracts for each payroll period. Non-exempt employees will be required to complete their time and effort reporting within our payroll module, which will maintain the record and electronic signatures. Any corrections will be collected and reconciled before the contract period is closed. Name(s) of the contact person(s) responsible for corrective action: Christopher Paris Planned completion date for corrective action plan: 6/30/2024

View Audit 293657 Questioned Costs: $1

Finding 372576 (2023-002)

None 2023

Ascentria Community Services, Inc.

MA

Questioned Costs Internal Control / Segregation of Duties

U.S. Department of Health and Human Services 2023-002 Unaccompanied Alien Children Program – Assistance Listing No. 93.676 Recommendation: It is recommended that the Organization design controls to ensure expenses are supported by source documentation. Explanation of disagreement with audit findi...

U.S. Department of Health and Human Services 2023-002 Unaccompanied Alien Children Program – Assistance Listing No. 93.676 Recommendation: It is recommended that the Organization design controls to ensure expenses are supported by source documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ascentria will review our current policy and procedures with directors and program managers regarding what proper support and approval process is for an expense. Ascentria has already implemented a monthly reminder that includes that expenses must include a receipt or invoice. Name(s) of the contact person(s) responsible for corrective action: Christopher Paris Planned completion date for corrective action plan: 6/30/2024

View Audit 293657 Questioned Costs: $1

Finding 372484 (2023-002)

Significant Deficiency 2023

Boise State University

ID

Questioned Costs Reporting Procurement, Suspension & Debarment § 200.303 § 200.502 § 200.510

Federal Program Title: Research and Development Cluster ALN: Various Recommendation: We recommend the University evaluate its cutoff procedures to ensure federal costs are identified and reported in the correct fiscal year. Explanation of disagreement with audit finding: There is no disagreement...

Federal Program Title: Research and Development Cluster ALN: Various Recommendation: We recommend the University evaluate its cutoff procedures to ensure federal costs are identified and reported in the correct fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Boise State University will evaluate our cutoff and accrual procedures to ensure costs are identified and reported in the correct fiscal year. Name(s) of the contact person(s) responsible for corrective action: Jen Lutke, Assistant Director, Post Award: jenniferlutke@boisestate.edu Planned completion date for corrective action plan: June 2024

View Audit 293651 Questioned Costs: $1

Finding 372381 (2023-004)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Questioned Costs Student Financial Aid Subrecipient Monitoring

GLBA non-compliance Finding: The University does not meet the compliance requirements outlined in the GLBA Safeguards Rule. Discrepancies were identified in requirement B.6 which addresses how the institution how the institution will oversee its information system service providers. The University ...

GLBA non-compliance Finding: The University does not meet the compliance requirements outlined in the GLBA Safeguards Rule. Discrepancies were identified in requirement B.6 which addresses how the institution how the institution will oversee its information system service providers. The University did not have a Vendor Management Program with standards in place to oversee critical system service providers regarding due diligence, risk assessments, and annual reviews as related to 3rd party service providers. Auditors' Recommendation: The University needs to review the updated GLBA requirements and ensure their WISP includes all required elements. School Response: The school agrees with this finding. Corrective Action Plan: The school's director of IT is reviewing the school's Written Information Security Plan (WISP) to ensure GLBA Compliance. A vendor management plan has been added to the WISP which specifies that any information technology vendors and products will be subjected to an IT Acquisition Process prior to use by the University. In the IT Acquisition Process, the vendors and products will be evaluated by the Information Technology Advisory Committee and the Office of Information Technology to determine impact on the current infrastructure and data systems as well as any security concerns that should be addressed prior to implementation. Name(s) of the contact person{s) responsible for corrective action: Point University Director of IT, Bill Dorminy Planned completion date for corrective action plan: • WISP and review of GLBA requirements is ongoing with completion of the current review expected by June 1, 2024.

View Audit 293636

Finding 372380 (2023-003)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Questioned Costs Student Financial Aid Eligibility

Pell Award Errors Finding: As noted in the audit report, there were 5 instances out of 60 students with Pell award errors. Auditors' Recommendation: The University should have appropriate policies and procedure, as well as safeguards in place to ensure Pell eligibility and awarding is correctly de...

Pell Award Errors Finding: As noted in the audit report, there were 5 instances out of 60 students with Pell award errors. Auditors' Recommendation: The University should have appropriate policies and procedure, as well as safeguards in place to ensure Pell eligibility and awarding is correctly determined. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: For student #5, there was a Pell awarding error where the student was under awarded Pell by $172. The school made the correction to the award and disbursed the additional Pell. For student #16, student was over awarded Pell Grant for $1723 due to incorrect refunds made while adjusting for changes in the student's schedule. The school has refunded the $1723 over award back to the fund source. For student #24, the student was initially awarded correctly, but withdrew during their 2nd term. Due to incorrect Pell Recalculation on the R2T4, the school refunded too much Pell grant, and the student was under awarded by $458. The school has disbursed the additional Pell so the student is now paid correctly. For student #27, the student was over awarded Pell by $350 due to in error in Pell Recalculation based on the student's schedule. The school has refunded the over award to the fund source. For student #43, the student was under awarded by $22 due to an error in Pell Recalculation based on the student's schedule. The school has disbursed the additional Pell grant funds to correct the error. Starting with the Fall 2023 semester the school has implemented a new student information system (SIS), Colleague. The school has also partnered with a third-party servicer, Financial Aid Services (FAS), to assist with packaging. The new SIS automatically adjusts Pell grant whenever there is a change to a student's schedule during the term through the school's census date for each term and module. The system will schedule a refund for any over awards and increase the Pell award for any that may have been under awarded. Since this is no longer reviewed solely by the financial aid office, this is expected to reduce the number of errors in Pell awarding. In addition to the system adjustments, the school's third-party servicer, FAS, will review packaging for any students with changes to the number of registered credits during the term to ensure the system is making adjustments properly and the students are correctly packaged. Name(s) of the contact person{s) responsible for corrective action: Financial Aid Director, Holly Hardnett and third-party servicer, FAS, representative Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training for Pell Recalculations in Colleague July 2023. • Registration/schedule changes for term reviewed by FAS at least weekly.

View Audit 293636 Questioned Costs: $1

Finding 372379 (2023-002)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Student Financial Aid Reporting Questioned Costs

NSLDS Enrollment Reporting (repeat) Finding: As noted in the audit report, there were 4 discrepancies found in 17 files in which student information reported to NSLDS was incorrect or untimely. • 2 students' status was incorrectly reported to NSLDS. • 1 student's enrollment effective date was not r...

NSLDS Enrollment Reporting (repeat) Finding: As noted in the audit report, there were 4 discrepancies found in 17 files in which student information reported to NSLDS was incorrect or untimely. • 2 students' status was incorrectly reported to NSLDS. • 1 student's enrollment effective date was not reported correctly to NSLDS. • 1 student's enrollment status change was not reported to NSLDS within 60 days. Auditors' Recommendation: The University should review their enrollment reporting policies and procedures to ensure accurate reporting. School Response: The school agrees with this finding and has initiated corrective action. Corrective Action Plan: There were two files in which NSLDS reporting errors were found. Student #12 was withdrawn per their school transcript effective 5/14/2023, however, the enrollment status was reported at NSLDS as Less Than Half Time as of 5/8/2023. Student #14 was in a Graduate status on their transcript but was reported as Withdrawn on NSLDS. Also, the student's status was reported 134 days after the status change event. Status changes must be reported to NSLDS within 60 days. The instances for this finding occurred during a time when there was a staffing change in the registrar's office and a new registrar had not yet transitioned into the position. Since this time, a new registrar, Natalie Brown-Motes, was hired, and the process has been reviewed with Assistant Registrar, Lara Ellison, to ensure that there is a back up plan if the registrar is unavailable to complete this process. Additionally, the school switched to a new Student Information System (SIS), Colleague, which was implemented beginning with the Fall semester 2023. The new SIS works with the National Student Clearinghouse enrollment reporting service. In order to ensure timely reporting, the registrar's office creates an enrollment report in Colleague each month. That report is transmitted to Clearinghouse which uses the information to update the enrollment data in NSLDS. If there are any possible errors that need to be reviewed, the registrar receives a report on Clearinghouse of any errors so they can be reviewed and approved or corrected. The error report must be completed within two weeks of receipt. Colleague only reports to Clearinghouse students who have actually registered for classes. Previously, enrolled students who had not registered were included in the report. This inclusion regularly generated additional errors. Since the new system improves the reporting process so only registered students are reported, there is less opportunity for error. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Natalie BrownMotes and Assistant Registrar, Lara Ellison Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on National Student Clearinghouse process with Colleague completed September 23. • Began using Colleague system to report enrollment data to NSLDS through National Student Clearinghouse in September 2023.

View Audit 293636

Finding 372378 (2023-001)

Significant Deficiency 2023

Point University, Inc. and Subsidiaries

GA

Questioned Costs Student Financial Aid Reporting

Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported t...

Disbursement Dates (repeat) Finding: As noted in the audit report, there were three instances in 60 files in which there were discrepancies in disbursement dates. Disbursement dates recorded on student accounts for Direct Loan and Pell disbursements did not agree to the disbursement date reported to Common Origination and Disbursement (COD). Auditors' Recommendation: The University should review their policies and procedures to ensure accurate reporting to COD. School Response: The University agrees with this finding and has initiated corrective action. Corrective Action Plan: Title IV disbursements must be posted to student accounts within 15 days of the funds drawdown. Also, the disbursement date per COD must match the disbursement date on the student account. There was one instance in which the Disbursement date for a Pell Grant was 10/10/2022 per COD and 10/19/2022 on the student's account. One instance had a disbursement date at COD as 2/16/2023 and at 2/15/2023 on the student's account. The third instance had a disbursement date of 1/25/23 at COD and 1/26/23 on the student's account. Each of these disbursements were posted in the old Student Information System (SIS), Anthology. The posting process that the school used under the previous system relied primarily on manual checks by employees in various departments in which reports could be sent to COD in which the posting dates did not match the COD dates. In order to avoid this finding in the future, the University has sought out and implemented a new Student Information System (SIS), Colleague, beginning with the 2023-24 award year. The school has also contracted with a third-party servicer, Financial Aid Services (FAS}, to assist with packaging students and completing the disbursement process. To disburse funds, the Director of Financial Aid Quality and Compliance or the representative from FAS runs a report in Colleague which pulls scheduled and approved financial aid disbursements for students who have met the enrollment criteria to receive those disbursements. The report goes to the student accounts office where the financial aid is posted to the student ledgers. Then it is transmitted to COD with the posted dates so that the dates reported to COD match the dates in the SIS. If there are any errors in the transmission, the Director of Financial Aid Quality and Compliance or the representative from FAS will review the rejected disbursements and make corrections to get them processed as quickly as possible. The accounting office submits the drawdown request to G-5 for the amount of the approved and posted financial aid. The new process in which the disbursement amounts and dates transmitted to COD match the disbursement amounts and dates posted to the students' ledgers is expected to ensure compliance in the future. Name(s) of the contact person(s) responsible for corrective action: Director of Financial Aid Quality and Compliance, Rachal Wortham Planned completion date for corrective action plan: • New Colleague SIS implemented live beginning in the Fall semester 2023. • Training on new disbursement process completed August 2023. • First disbursements approved using the new SIS done by Director of Financial Aid Quality and Compliance August 2023. • Review of disbursement process with FAS October 2023. • Follow up with Colleague team to review the process and work out any flaws February 2024.

View Audit 293636

Finding 372326 (2023-003)

Significant Deficiency 2023

Carteret Board of Education

NJ

Questioned Costs Cash Management Reporting

The District will implement processes and procedures for the timely liquidation of all POs to ensure that expenditures are captured and are in agreement with the final federal grant expenditure report.

View Audit 293633

Finding 372322 (2023-001)

Significant Deficiency 2023

Carteret Board of Education

NJ

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

The District developed the Carteret Public Schools Federal Procurement Procedures to meet the criteria required by the Uniform Grant Guidance.

View Audit 293633

Finding 372297 (2023-004)

None 2023

North Dade Senior Citizens Housing Developement Corporation, Inc., Rsi

FL

HUD Housing Programs Questioned Costs Subrecipient Monitoring

FINDING No. 2023-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should improve monitoring of the payroll disbursement process to ensure the appropriate approved wages are paid. Action Taken: Additio...

FINDING No. 2023-004: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should improve monitoring of the payroll disbursement process to ensure the appropriate approved wages are paid. Action Taken: Additional payroll controls are being evaluated and implemented in 2024. This will include establishing procedures to ensure the completeness and accuracy of payroll and related oversight. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

View Audit 293594 Questioned Costs: $1

Finding 372296 (2023-003)

None 2023

North Dade Senior Citizens Housing Developement Corporation, Inc., Rsi

FL

HUD Housing Programs Questioned Costs Reporting

FINDING No. 2023-003: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should make sufficient monthly deposits to the escrow accounts in a timely manner. Action Taken: The shortfall was due to the property...

FINDING No. 2023-003: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: The Project should make sufficient monthly deposits to the escrow accounts in a timely manner. Action Taken: The shortfall was due to the property insurance premium unexpectedly increasing by more than $170,000. The account was subsequently analyzed, and the monthly escrow deposit is now sufficient to cover the new rates.

View Audit 293594 Questioned Costs: $1

Finding 372280 (2023-002)

Significant Deficiency 2023

Sweet Briar Institute

VA

Internal Control / Segregation of Duties Questioned Costs Reporting

Individuals Responsible for Corrective Action Plan Wanda Spradley, Director, Financial Aid Susan Kennon, Registrar Jennifer Sauer, AVP for Finance Corrective Action Plan: The college made every attempt to meet the myriad of requirements throughout the various HEERF funding periods, with ever cha...

Individuals Responsible for Corrective Action Plan Wanda Spradley, Director, Financial Aid Susan Kennon, Registrar Jennifer Sauer, AVP for Finance Corrective Action Plan: The college made every attempt to meet the myriad of requirements throughout the various HEERF funding periods, with ever changing forms and due dates. The quarterly report noted was the final reporting requirement for all HEERF funds received by the college. Since no further reports are required, there is no action taken. Anticipated Completion Date: N/A

View Audit 293553

Finding 372272 (2023-003)

Significant Deficiency 2023

Northwestern Health Sciences University

MN

Questioned Costs Student Financial Aid Significant Deficiency

Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Man...

Recommendation: We recommend that the University implement a procedure to ensure that all necessary MPNs are retained in accordance with the federal regulation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the audit finding where some MPNs are missing. We are unable to correct the past but moving forward, the new ones are being retained. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: September 1, 2023

View Audit 293548

Finding 372267 (2023-004)

Significant Deficiency 2023

Northwestern Health Sciences University

MN

Questioned Costs Student Financial Aid Significant Deficiency

Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Acti...

Recommendation: We recommend that the University review its procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agree with the audit finding and will implement procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: Already in place

View Audit 293548 Questioned Costs: $1

Finding 372262 (2023-002)

Significant Deficiency 2023

Northwestern Health Sciences University

MN

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with t...

Recommendation: We recommend that the University review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and will be implementing new written policies related to the recent GLBA changes. Name of the contact person responsible for corrective action: Michelle Hegarty, CFO Planned completion date for corrective action plan: In process.

View Audit 293548

Finding 372257 (2023-001)

Significant Deficiency 2023

Northwestern Health Sciences University

MN

Questioned Costs Student Financial Aid Reporting

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 ta...

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: Management agrees with the audit finding and will pull a sample of records each week after each NSC submission to ensure information has been passed onto NSLDS. Name of the contact person responsible for corrective action: Kris Ragozzino, Registrar Planned completion date for corrective action plan: Already in place.

View Audit 293548

Finding 372226 (2023-001)

Significant Deficiency 2023

Absaroka, INC

WY

Procurement, Suspension & Debarment Questioned Costs Significant Deficiency

Absaroka Inc. has amended their procurement procedure effective 2/7/2024 by adding the following to the Accounting Policies Manual: Debarment and Suspension (E.O.s 12549 and 12689): No contract shall be made to the parties listed on the General Services List of Parties Excluded from Federal Procure...

Absaroka Inc. has amended their procurement procedure effective 2/7/2024 by adding the following to the Accounting Policies Manual: Debarment and Suspension (E.O.s 12549 and 12689): No contract shall be made to the parties listed on the General Services List of Parties Excluded from Federal Procurement or Non-procurement Programs in accordance with E.O.'s 12549 and 12689, "Debarment and Suspension." This list contains the names of parties debarred, suspended or otherwise excluded by agencies and contractors declared ineligible under statutory or regulatory authority other than E.O. 12549. Contractors with awards that exceed the federally-defined simple acquisition threshold ($100,000) shall provide the required certification regarding their exclusion status and that of their principle employees. Absaroka, Inc. shall review the list of excluded parties found on www.sam.gov and verify exclusion status from all vendors for purchases greater than $25,000.

View Audit 293524

Finding 372188 (2023-002)

Significant Deficiency 2023

University of Cincinnati

OH

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding Number: 2023-002 Condition: Out of 60 allowability samples that were tested, one expenditure tested was determined to be incorrectly charged to this grant. Planned Corrective Action: The College of Cooperative Education and Professional Studies (CCPS) has instituted several reforms to prev...

Finding Number: 2023-002 Condition: Out of 60 allowability samples that were tested, one expenditure tested was determined to be incorrectly charged to this grant. Planned Corrective Action: The College of Cooperative Education and Professional Studies (CCPS) has instituted several reforms to prevent future instances of this nature. The Program Director is now required to review and sign-off on all transactions before they are charged to the project, to ensure all charges are appropriate. New staff have been assigned to the project to process transactions, and the CCPS business office is now meeting monthly to review project activity, discuss any questions, and address any concerns regarding financial activities. Additionally, the university is drafting a new policy to review and, if needed, provide additional administrative support for large, complex grant projects. This policy will require that grant proposals above a certain dollar threshold are reviewed by the Office of Research prior to submission to ensure proper resources will be available to manage the project if awarded. In cases where the Office of Research determines additional resources may be needed, they will be authorized to require additional support be included in the grant proposal, or else provide additional administrative help to the unit at the time of award. Contact person responsible for corrective action: CCPS: Jeremy Harvey, Jodi Sleyo, and Bailey Bartels. Office of Research: Patrick Clark Anticipated Completion Date: CCPS changes have been implemented as of 10/11/2023; policy changes to be completed by 6/30/2024.

View Audit 293505 Questioned Costs: $1

Finding 372180 (2023-001)

Significant Deficiency 2023

University of Cincinnati

OH

Subrecipient Monitoring Questioned Costs Procurement, Suspension & Debarment § 200.305

Finding Number: 2023-001 Condition: Out of 28 payments to subrecipients that were tested, 12 were made after the 30 calendar day requirement. Planned Corrective Action: Accounts Payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expendit...

Finding Number: 2023-001 Condition: Out of 28 payments to subrecipients that were tested, 12 were made after the 30 calendar day requirement. Planned Corrective Action: Accounts Payable personnel will review all vendor invoices to determine whether an invoice is related to a federal award expenditure. For federal award expenditures, Accounts Payable will manually change the payment terms to 30 calendar days or less, to ensure compliance. Periodically, Accounts Payable will review open federal award payables to verify payment terms have been properly set for the 30-day compliance requirement. The Controller’s and Accounts Payable Offices will also explore creating a more efficient long-term solution, whereby the 30-day terms could be automatically set during the purchase order creation process. This would eliminate any manual updates to the payment terms by Accounts Payable personnel. The Sponsored Research Services Accounting Office will send reminders to all college business officers and Principal Investigators (PIs) to highlight the need for prompt review and approval of Federal award invoices. This language will be incorporated into the SRS Best Grant Practices training classes, as well as the university’s Fundamentals of Sponsored Administration training courses. Contact person responsible for corrective action: Accounts Payable: Erik Sager; Purchasing: Tom Guerin; Sponsored Research Services Accounting: John Ungruhe Anticipated Completion Date: Initial corrective action, including review of invoices, reminders and modifications to training, will be completed by 10/31/2023. Additional solutions to eliminate manual updates, if possible, will be completed within 12 months.

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