Corrective Action Plans

Finding 4368 (2023-006)

Significant Deficiency 2023

Housing Opportunities Commission of Montgomery County, MD

MD

HUD Housing Programs Questioned Costs Eligibility

Recommendation: The Commission should implement processes to ensure that waiting list documentation is maintained for all tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new procedure will be implemented...

Recommendation: The Commission should implement processes to ensure that waiting list documentation is maintained for all tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new procedure will be implemented immediately requiring staff to upload a printed copy of the electronic wait list application along with the move in file. The Edgewood compliance team to verify that the applicant was selected from the waitlist prior to move-in approval. Name(s) of the contact person(s) responsible for corrective action: Darcel Cox, Vice President/Compliance Planned completion date for corrective action plan: Effective Immediately, Ongoing.

View Audit 6779

Finding 4359 (2023-002)

Material Weakness 2023

Housing Opportunities Commission of Montgomery County, MD

MD

Questioned Costs HUD Housing Programs Material Weakness

Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC has hi...

Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC has hired a new Inspections contractor, Gilson Housing Partners, to conduct all inspections effective October 1, 2023. Gilson Housing Partners will send HOC detailed weekly reports of all inspection activity, including failed units, units requiring abatement, scheduled/rescheduled inspections, and quality control reports. HOC will monitor these reports to ensure they meet program requirements. Gilson will also meet with HOC staff monthly to discuss progress and program operations. Designated staff members will be assigned to place/remove units in abatement. Bi-monthly, the HOC Compliance Team conducts quality control reviews of completed actions. Following completion, staff from the Housing Resources Management, Inspections and HOC Compliance Teams meet to discuss systemic findings and schedule staff training in areas requiring improvement. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President/Housing Resources Planned completion date for corrective action plan: October 2023

View Audit 6779 Questioned Costs: $1

Finding 4334 (2023-002)

Significant Deficiency 2023

Texas Wesleyan University

TX

Student Financial Aid Reporting Questioned Costs

Finding Number: 2023-002 Corrective Action: Enrollment reporting is performed by the Office of Student Records. The new university registrar has modified the enrollment reporting process to include audits of all student-related data prior to census day. Any changes in student academic program receiv...

Finding Number: 2023-002 Corrective Action: Enrollment reporting is performed by the Office of Student Records. The new university registrar has modified the enrollment reporting process to include audits of all student-related data prior to census day. Any changes in student academic program received after census day will be effective for the next academic semester. Additionally, the registrar created procedural changes to ensure reporting happens for every reporting period with the added redundancy of additional staff. All reporting periods are recorded on the Office of Student Records’ office calendar and in their processing action plan document. Responsible: Karen Jarrell, University Registrar Completion Date: November 1, 2023

View Audit 6750

Finding 4323 (2023-003)

Significant Deficiency 2023

Richardton Health Center

ND

Questioned Costs Special Tests & Provisions Significant Deficiency § 200.303

Finding 2023‐003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the b...

Finding 2023‐003 Federal Agency Name: Department of Agriculture Program Name: Community Facilities Loans and Grants CFDA #10.766 Finding Summary: There was no formal review separate from the preparer over the reserve fund reconciliation for the federal program and there was no formal review of the balance in comparison to the required minimum reserve balance. Responsible Individuals: Mandy Robinson, Administrator Corrective Action Plan: Management will ensure reviews separate from the preparer of the reconciliation for the program's reserve fund and the reserve fund balance in comparison to the required minimum reserve balance is completed with formal documentation noting the reviews. Anticipated Completion Date: 03/31/2024

View Audit 6716

Finding 4313 (2023-003)

Material Weakness 2023

Mount Marty University

SD

Student Financial Aid Questioned Costs Subrecipient Monitoring

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program (PELL) P063P202209, P063P212209, P063P222209 Finding 2023-003 – Eligibility – Material Weakness Finding Summary: Two instances identified in which the s...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing #84.063 Federal Pell Grant Program (PELL) P063P202209, P063P212209, P063P222209 Finding 2023-003 – Eligibility – Material Weakness Finding Summary: Two instances identified in which the student was eligible to receive Federal Pell assistance but was not awarded the assistance. Responsible Individuals: Lauren Svanda, Director of Financial Aid Corrective Action Plan: Partake in additional training in the awarding of summer PELL. Update procedures on how information is communicated between the Registrar’s Office and Financial Aid to improve awareness of summer reporting and grade change updates. Recondition the reporting process to improve accuracy of delivered information. Anticipated Completion Date: January 1st, 2024

View Audit 6701 Questioned Costs: $1

Finding 4296 (2023-001)

Significant Deficiency 2023

Unity Environmental University

ME

Student Financial Aid Questioned Costs HUD Housing Programs

Finding 2023-001 Correc􀆟ve Ac􀆟on Plan This is a response to Finding 2023-001 listed in the Schedule of Findings and Ques􀆟oned Costs for Federal Awards. Unity Environmental University agrees with this finding and has taken the following correc􀆟ve ac􀆟ons to prevent recurrence of such findings. While t...

Finding 2023-001 Correc􀆟ve Ac􀆟on Plan This is a response to Finding 2023-001 listed in the Schedule of Findings and Ques􀆟oned Costs for Federal Awards. Unity Environmental University agrees with this finding and has taken the following correc􀆟ve ac􀆟ons to prevent recurrence of such findings. While tes􀆟ng the return of Title IV funds, a nonsta􀆟s􀆟cal sample of 25 students was tested for proper return calcula􀆟ons. During the tes􀆟ng, 1 of 25 calcula􀆟ons were incorrectly calculated. The error did not result in addi􀆟onal funds to be returned. The student in ques􀆟on had a􀆩ended one module of two in the graduate program payment period. When the recalcula􀆟on was performed, the full payment period was used. The student had earned 100% of aid due to comple􀆟ng 60% of the period. The error was not caught by the second reviewer. This occurred during a 􀆟me of low staffing in the financial aid office and a high volume of ac􀆟vity. The calcula􀆟on was corrected but no addi􀆟onal funds needed to be returned as the student s􀆟ll earned 100% of aid due to comple􀆟ng 60% of the module. In an abundance of cau􀆟on, the financial aid staff reviewed R2T4 calcula􀆟ons completed for all graduate students. No addi􀆟onal errors were found. The financial aid staff met to discuss the finding and management emphasized the impact to the student and ins􀆟tu􀆟on when these errors occur. We believe this was an isolated incident and the staff understands the importance of the second reviewer role to avoid such errors. Responsible Person: Sherry Watson Correction Date: 06/27/23

View Audit 6639

Finding 4289 (2023-001)

None 2023

13west 103rd Street CORP

NY

HUD Housing Programs Questioned Costs Cash Management

Actions Taken or Planned - Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Management has determined that making the required deposit will leave the entity with low funds to cover operation expenses. Management is currently i...

Actions Taken or Planned - Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Management has determined that making the required deposit will leave the entity with low funds to cover operation expenses. Management is currently in communication with HUD discussing options of a possible waiver for the required deposit or the possibility of making the deposit with promise of approval for immediate release

View Audit 6603

Finding 4288 (2023-001)

None 2023

1347 Morris Avenue Corporation

NY

HUD Housing Programs Questioned Costs Cash Management

Actions Taken or Planned - Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Management has determined that making the required deposit will leave the entity with low funds to cover operation expenses. Management is currently i...

Actions Taken or Planned - Auditee agrees with this finding. Our policy has been to make surplus cash deposits after the final audit has been issued. Management has determined that making the required deposit will leave the entity with low funds to cover operation expenses. Management is currently in communication with HUD discussing options of a possible waiver for the required deposit or the possibility of making the deposit with promise of approval for immediate release

View Audit 6601

Finding 4285 (2023-002)

Material Weakness 2023

Town of Hingham, Massachusetts

MA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Questioned Costs § 200.430

Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that ...

Hingham Public Schools has circulated training guides and templates to grant writers on the requirement to have time and effort reporting completed in a timely manner for staff assigned to specific grants. Grant accounting associates have also been provided with the training material to ensure that there is an additional review of time and effort reports as part of the grant accounting, review and finalization process.

View Audit 6595 Questioned Costs: $1

Finding 4276 (2023-006)

Significant Deficiency 2023

City Colleges of Chicago

IL

Student Financial Aid Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.303

Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic i...

Finding 2023-006– Gramm-Leach Bliley Act—Student Information Security Condition City Colleges did not have a documented policy to address a required safeguard for one of the eight required elements under the Gramm-Leach Bliley Act (GLBA). Specifically, the City Colleges did not conduct a periodic inventory of data, nothing where it’s collected, stored or transmitted. Cause City Colleges does not have a periodic data inventory in place. The policy is under development with an expected completion date of December 2023. Corrective Action Taken or Planned CCC will refresh the current data inventory and instate periodic inventory refresh procedures by December 31, 2023. Contact Person: Zarko Njakara, Interim CIO Anticipated Completion Date: December 31, 2023

View Audit 6574

Finding 4270 (2023-004)

Significant Deficiency 2023

City Colleges of Chicago

IL

Questioned Costs Student Financial Aid Cash Management § 200.303

Finding 2023-004 – Cash Management – Excess Cash Condition During our cash management testing, we identified the following instances of excess cash: • Kennedy King College had excess cash for the Pell Grant Program ranging from $34,408 to $175,609 during the period of November 14, 2022 through Jan...

Finding 2023-004 – Cash Management – Excess Cash Condition During our cash management testing, we identified the following instances of excess cash: • Kennedy King College had excess cash for the Pell Grant Program ranging from $34,408 to $175,609 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Kennedy King College had excess cash for the Direct Loan Program ranging from $1,349 to $4,318 during the period of November 29, 2022 through December 13, 2022, from $1,508 to $3,948 during the period of January 6, 2023 through January 16, 2023 and from $3,207 to $5,137 during the period of June 15, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns, however, amounts were not returned within a seven-day period. • Truman College had excess cash for the Pell Grant Program ranging from $164,625 to $262,034 during the period of November 14, 2022 through January 31, 2023. In these situations, the excess cash exceeded one percent of total prior year drawdowns and amounts were not returned within a seven-day period. • Truman College had excess cash for the Direct Loan Program ranging from $2,731 to$8,669 during the period of January 20, 2023 through February 16, 2023 and from $752 to $10,028 during the period of April 28, 2023 through June 29, 2023. In these situations, the excess cash did not exceed one percent of total prior year drawdowns; however, amounts were not returned within a seven-day period. Cause The College drew down funds available in the G5 system as opposed to drawing down expected student disbursement amounts. Corrective Action Taken or Planned District Office Financial Aid will develop and implement better controls and procedures for monitoring the timing of the draw downs and student disbursements as well as controls to monitor the return of excess cash, if any, within the 7-day period. During the middle of a semester, timely reconciliations will be prepared, reviewed and approved prior to the next draw down to ensure the acceptable amount is drawn down and disbursed timely to the students. Contact Person: Tiffany Morrison, Associate Vice Chancellor, Financial Aid Anticipated Completion Date: December 31, 2023

View Audit 6574 Questioned Costs: $1

Finding 4263 (2023-004)

Material Weakness 2023

W-A-Y Academy

MI

Questioned Costs Cash Management

Management believes that the previous Director of Finance drew down the funds in error. Going forward, a record of all funds drawn will be maintained and will include documentation to support the amount of the drawdown.

View Audit 6573 Questioned Costs: $1

Finding 4240 (2023-008)

None 2023

God's Bible School, College and Missionary Training Home

OH

Student Financial Aid Questioned Costs

The School returned the $2,585.50 in question to the Department of Education on September 6, 2023. Communication will be improved between the various offices on campus. Policies and procedures are being reviewed and updated, as needed, for the students participating in on-line courses. Anticipated C...

The School returned the $2,585.50 in question to the Department of Education on September 6, 2023. Communication will be improved between the various offices on campus. Policies and procedures are being reviewed and updated, as needed, for the students participating in on-line courses. Anticipated Completion Date: The corrective action was completed on September 6, 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

View Audit 6551 Questioned Costs: $1

Finding 4238 (2023-005)

None 2023

God's Bible School, College and Missionary Training Home

OH

Student Financial Aid Questioned Costs Special Tests & Provisions

Management agrees with the auditors’ finding. Federal Pell Grant funds are entitlement funds and cannot be returned. The student in question also worked the hours in which Federal Work Study funds were awarded. Going forward, the School has made changes to the provisions of the institutional scholar...

Management agrees with the auditors’ finding. Federal Pell Grant funds are entitlement funds and cannot be returned. The student in question also worked the hours in which Federal Work Study funds were awarded. Going forward, the School has made changes to the provisions of the institutional scholarship to avoid overawards. All state and federal aid and endowed scholarships are applied first and then the scholarship covers the remaining tuition cost. The corrective action was completed in September 2023. Contact Person Valorie Quesenberry, Financial Aid Coordinator 513-763-6659

View Audit 6551 Questioned Costs: $1

Finding 4224 (2023-002)

Significant Deficiency 2023

Centenary College of Louisiana

LA

Subrecipient Monitoring Questioned Costs Special Tests & Provisions

Regarding finding 2023-002, Due to costs associated with full and immediate implementation, The College use a phased approach and will continue to make progress of meeting the federal standards related to the GLBA security program. The college expects to at minimum 80% in compliance by the end of FY...

Regarding finding 2023-002, Due to costs associated with full and immediate implementation, The College use a phased approach and will continue to make progress of meeting the federal standards related to the GLBA security program. The college expects to at minimum 80% in compliance by the end of FY24 and in full compliance by the end of FY25. The college will prioritize key elements such as reviewing access controls, implementing multi-factor authentication for the campus, disposing of student information securely, performing annual penetration testing, and encrypting all the institution's information. ECD: June 30, 2026. Action Officer: Mr. Scott Merritt, Director of Information and Technology & CIO.

View Audit 6549

Finding 4220 (2023-001)

Significant Deficiency 2023

Centenary College of Louisiana

LA

Student Financial Aid Questioned Costs Special Tests & Provisions

Regarding finding 2023-001, The Financial Aid Director will no longer enter the dates of semesters/sessions in the Banner ERP system. The Registrar will assume responsibility for this task and work in conjunction with directors of Financial Aid and the MBA program to ensure term dates are establishe...

Regarding finding 2023-001, The Financial Aid Director will no longer enter the dates of semesters/sessions in the Banner ERP system. The Registrar will assume responsibility for this task and work in conjunction with directors of Financial Aid and the MBA program to ensure term dates are established when needed and accurately maintained. ECD: Effective immediately. Action Officer: Dr. Lolita Rogers, Registrar.

View Audit 6549

Finding 4215 (2023-001)

Significant Deficiency 2023

Realife Cooperative of St. Peter

MN

Questioned Costs Reporting Internal Control / Segregation of Duties

Housing and Urban Development Realife Cooperative of St. Peter respectfully submits the following corrective action plan for the year ended September 30, 2023. Westberg Eischens, PLLP 2630 1st Street South P.O. Box 362 Willmar, MN 56201 Audit Period: September 30, 2023 The finding from the Septe...

Housing and Urban Development Realife Cooperative of St. Peter respectfully submits the following corrective action plan for the year ended September 30, 2023. Westberg Eischens, PLLP 2630 1st Street South P.O. Box 362 Willmar, MN 56201 Audit Period: September 30, 2023 The finding from the September 30, 2023 schedule of findings and questioned costs and the summary schedule of prior audit findings is discussed below. The finding is numbered consistently with the number assigned in the schedules. Summary of audit results does not include findings and is not addressed. Finding 2023-001 Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 6538

Finding 4214 (2023-001)

Significant Deficiency 2023

City of Norco

CA

Questioned Costs Reporting Significant Deficiency

There is no disagreement with the audit finding. The City will make corrections on the next annual report as of March 31,2024 which should cover the period April 1 2023 through March 31, 2024. As of June 30, 2023, the City had fully expended the American Resue Plan Act (ARPA) funding. It is importan...

There is no disagreement with the audit finding. The City will make corrections on the next annual report as of March 31,2024 which should cover the period April 1 2023 through March 31, 2024. As of June 30, 2023, the City had fully expended the American Resue Plan Act (ARPA) funding. It is important to note that because the City's allocation of ARPA funds is less than $10 million, the Department of Treasury Regulations allows the City to use all its allocation as lost revenue replacement. This allows the City Council to appropriate ARPA funds for any legal government purpose except those that are prohibited. The City treated all its allocation as lost revenue replacement.

View Audit 6534

Finding 4213 (2023-001)

Significant Deficiency 2023

Kane County School District

UT

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.326

(1) Any contracts over $2,000 will include the proper language that the contractor must comply with the Davis-Bacon Act. These contracts will be reviewed by Business Administrator and Superintendent before being signed and (2) Weekly certified reports will be obtained from contractor and reminders h...

(1) Any contracts over $2,000 will include the proper language that the contractor must comply with the Davis-Bacon Act. These contracts will be reviewed by Business Administrator and Superintendent before being signed and (2) Weekly certified reports will be obtained from contractor and reminders have been set up with both parties to ensure this happens timely. Person Responsible: Cary Reese, Business Administrator Timeline: Management of the District will ensure all construction contracts using federal dollars will have the Davis-Bacon language in the contract-October 2023. Certified weekly payroll reports obtained from contractor-October 2023.

View Audit 6529

Finding 4212 (2023-003)

Significant Deficiency 2023

Merton Community School District

WI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Corrective Action Plan: The District will initiate the development of an equipment tracking system that adheres to federal requirements. Training sessions will be conducted for relevant staff to ensure proper understanding and compliance with the new tracking procedures.

View Audit 6526

Finding 4211 (2023-002)

Significant Deficiency 2023

Merton Community School District

WI

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Corrective Action Plan: The District will promptly establish policies and procedures related to the Davis-Bacon Act, conduct training sessions for relevant staff, and assign dedicated personnel to monitor compliance on an ongoing basis. A corrective action plan will be implemented to ensure full com...

Corrective Action Plan: The District will promptly establish policies and procedures related to the Davis-Bacon Act, conduct training sessions for relevant staff, and assign dedicated personnel to monitor compliance on an ongoing basis. A corrective action plan will be implemented to ensure full compliance with federal regulations.

View Audit 6526

Finding 4192 (2023-002)

Significant Deficiency 2023

City of Springfield

KY

Questioned Costs Internal Control / Segregation of Duties

Upon receiving the notification that there was an inconsistency in our payroll, we immediately took the recommendation that we should have a second individual review payroll prior to submission. In addition to this, we have made the decision to leave the payroll company that we contracted with in Ma...

Upon receiving the notification that there was an inconsistency in our payroll, we immediately took the recommendation that we should have a second individual review payroll prior to submission. In addition to this, we have made the decision to leave the payroll company that we contracted with in March of this year (2023) and will begin processing payroll in house again. We made this decision due to various inconsistencies with the payroll company, including improper tax reporting and issues with pay rates changing after being entered. With the switch back to processing in house, we will continue to have two individuals review payroll before it is submitted.

View Audit 6504 Questioned Costs: $1

Finding 4175 (2023-003)

Significant Deficiency 2023

Borger Junior College District

TX

Procurement, Suspension & Debarment Questioned Costs § 200.321

The College agrees with the recommendation to update the procurement manual to maintain compliance related to contracting with small and minority business, women’s business enterprises, and labor surplus firms.

View Audit 6498

Finding 4173 (2023-001)

None 2023

Kishwaukee College

IL

Questioned Costs Student Financial Aid Eligibility

2023-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2023 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct L...

2023-001 Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.063, 84.268, Grant Period - Year Ended June 30, 2023 Condition Found During our student file testing we noted one student out of forty was disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need this student was eligible for $1,750 in Subsidized Loans and $1,000 in Unsubsidized Loans; however, the College awarded the student $1,750 in Subsidized loans and $1,250 in Unsubsidized loans which resulted in an over award of $250 in Unsubsidized Loans. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan During the audit for the year ending Jun 30, 2023, the financial aid office reviewed the finding and was able to refund the over-award of $250 in Unsub within the student’s loan period. Since the finding our Financial Aid Coordinator completed additional trainings related to the administration of Financial Aid. Within these trainings, successful completion of loan processing training was required. As of May 12, 2023, our Financial Aid Coordinator is a certified Financial Aid Administrator through the National Association of Financial Aid Administrators. Responsible Person for Corrective Action Plan Gregory Putra, Director of Financial Aid & Veterans Affairs Implementation Date of Corrective Action Plan 7/1/2023

View Audit 6494 Questioned Costs: $1

Finding 4169 (2023-002)

Material Weakness 2023

Elkhorn Area School District

WI

Questioned Costs School Nutrition Programs Eligibility

Corrective Action Plan: The District will put procedures back in place to make sure we are using current eligibility procedures (applications) to determine student eligibility. Anticipated Corrective Action Plan Completion Date: August 15, 2023 ...

Corrective Action Plan: The District will put procedures back in place to make sure we are using current eligibility procedures (applications) to determine student eligibility. Anticipated Corrective Action Plan Completion Date: August 15, 2023 Contact Information: For additional information regarding this finding please contact Bill Trewyn, Business Manager, at 262-741-9143.

View Audit 6493 Questioned Costs: $1

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