Corrective Action Plans

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Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Multi-Factor Authentication: The University’s Compliance Committee, led by the Chief Financial Officer, now requires that Multi Factor Authentication (MFA) is turned on for all MFA capable software systems that house Sensitive...
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: Multi-Factor Authentication: The University’s Compliance Committee, led by the Chief Financial Officer, now requires that Multi Factor Authentication (MFA) is turned on for all MFA capable software systems that house Sensitive Personally Identifiable Information of students. The Committee will implement policies to ensure that all users who access those systems are required to use Multi Factor Authentication. Any legacy systems without MFA will be retired. Information System Monitoring/Testing: In June of 2023, the University entered into a contract with an outside Managed IT Services provider. This third-party vendor provides the following services: • Firewall to protect network perimeter. • Security updates and critical patches. • Alerts to inform about issues on all endpoints. • Defense agents that scan and monitor external devices. • Agents to actively monitor web traffic and block malicious links. • Tools used for internal and external vulnerability scans. • Alerts to monitor for any malicious activity or events of potential compromise. • Other advanced threat protection. The University's Compliance Committee will assess the effectiveness of the existing continuous monitoring procedures and ascertain whether further vulnerability assessments and penetration testing are necessary to meet the stipulated criteria within Title 16, Chapter I, Subchapter C, Part 314 of the Federal Trade Commission regulations. The Compliance Committee will collaborate with additional IT Security Professionals as deemed necessary and ensure that the University is in compliance with the regulations. Person Responsible for Corrective Action Plan: David Entler, Chief Financial Officer Anticipated Date of Completion: January 31, 2024
Need Analysis Planned Corrective Action: We pull a report each term to verify that students have not been over or under awarded need-based aid or over or under awarded for their COA. We have added a step to our report that is specifically checking that subsidized eligibility has been maximized whe...
Need Analysis Planned Corrective Action: We pull a report each term to verify that students have not been over or under awarded need-based aid or over or under awarded for their COA. We have added a step to our report that is specifically checking that subsidized eligibility has been maximized when a student has both subsidized and unsubsidized loans. This is completed after students have accepted their aid so it will allow us to catch if a student accepted part of both types of loans and make the necessary correction. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director Anticipated Date of Completion: 10/27/23
Noncompliance with Federal Work Study/Federal Work Colleges Regulations Planned Corrective Action: The federal funds have been returned and re-disbursed to the student with only institutional funds (Practical Training Tuition Scholarship). We have added a checklist to our SAP report for students who...
Noncompliance with Federal Work Study/Federal Work Colleges Regulations Planned Corrective Action: The federal funds have been returned and re-disbursed to the student with only institutional funds (Practical Training Tuition Scholarship). We have added a checklist to our SAP report for students who go on Financial Suspension due to not meeting SAP to make sure each award is addressed. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director Anticipated Date of Completion: 10/27/23
View Audit 3792 Questioned Costs: $1
Incorrect and Untimely Return of Title IV (R2T4) Calculations Planned Corrective Action: The academics and financial aid office will work in conjunction to run a zero-credit earned report at the end of each term and determine if there are any unidentified unofficial withdrawals that must be process...
Incorrect and Untimely Return of Title IV (R2T4) Calculations Planned Corrective Action: The academics and financial aid office will work in conjunction to run a zero-credit earned report at the end of each term and determine if there are any unidentified unofficial withdrawals that must be processed. Throughout the semester the academics department is logging attendance daily to ensure students do not fail for non-attendance and are not missing more than five without proper notice. For students in online courses, professors will check in on student engagement every two days, and the academic administrative team will do a check once a week to identify any students who may be an unofficial withdrawal. For the calendar for R2T4’s the Financial Aid office keeps an excel sheet with the term dates and breaks for the year and will manually check that the dates/percentages align with the calculations on the COD R2T4 calculator. The first couple of students processed will be calculated manually with the information in the excel sheet to ensure it aligns with the calculation completed on COD. Person Responsible for Corrective Action Plan: Anna Bergh, Financial Aid Director and Tiffany Garrison, Interim Registrar Anticipated Date of Completion: 10/27/23
The District has designated an individual to review grant expenditures for proper compliance with grant requirements in tandem with the Business Manager's review of transactions for proper classification.
The District has designated an individual to review grant expenditures for proper compliance with grant requirements in tandem with the Business Manager's review of transactions for proper classification.
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The school’s student information system vendor did not offer multi-factor authentication (MFA) capability during or prior to the year under audit. This capability has just become available for their software as of October 2023....
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: The school’s student information system vendor did not offer multi-factor authentication (MFA) capability during or prior to the year under audit. This capability has just become available for their software as of October 2023. The school has requested access to this capability from the vendor and will be coordinating implementation of MFA as soon as possible. The written annual report will be modified to include all required areas based on updated regulations. Person Responsible for Corrective Action Plan: Debra Kellar, VP of Finance and Campus Operations Anticipated Date of Completion: March 31, 2024
Right to Cancel Notifications Planned Corrective Action: New student information system (Campus Café) provides an automated email to students that once funds are disbursed they are notified. I will edit the email to include the information about the Right to Cancel including instructions. Person ...
Right to Cancel Notifications Planned Corrective Action: New student information system (Campus Café) provides an automated email to students that once funds are disbursed they are notified. I will edit the email to include the information about the Right to Cancel including instructions. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: 01/06/2024, before the spring disbursement.
Lack of Documentation of Exit Counseling Planned Corrective Action: New student information system (Campus Café) is set to send automatic message when a student is set to Withdrawn. The email notifies them of their responsibility to complete the exit counseling along with the link to the website. ...
Lack of Documentation of Exit Counseling Planned Corrective Action: New student information system (Campus Café) is set to send automatic message when a student is set to Withdrawn. The email notifies them of their responsibility to complete the exit counseling along with the link to the website. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.
Return of Title IV (R2T4) Calculations Planned Corrective Action: Set the calendar to match academic calendar and set up for awarding in COD. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.
Return of Title IV (R2T4) Calculations Planned Corrective Action: Set the calendar to match academic calendar and set up for awarding in COD. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.
Enrollment Reporting to NSLDS Planned Corrective Action: Enroll in The National Clearing house to make reporting more automated and accurate. Set calendar reminder to send reports on a monthly schedule to make sure we report timely and accurately. Person Responsible for Corrective Action Plan: St...
Enrollment Reporting to NSLDS Planned Corrective Action: Enroll in The National Clearing house to make reporting more automated and accurate. Set calendar reminder to send reports on a monthly schedule to make sure we report timely and accurately. Person Responsible for Corrective Action Plan: Stephanie Castillo, Director of Financial Aid Anticipated Date of Completion: Fall 2023.
October 5, 2023 To: United States Department of Health and Human Services Generations Family Health Center, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: June 30, 2023 The findings f...
October 5, 2023 To: United States Department of Health and Human Services Generations Family Health Center, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINANCIAL STATEMENT FINDINGS: Finding 2023.001- Sliding Fee Scale Documentation Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated based on family size and income. Action Taken: Upon review of the finding, it was determined that the system calculated the slide correctly, but the procedure code was assigned to the incorrect procedure class, creating the error. Beginning July 1, 2023, Management has: • Reviewed the entire fee schedule, schedule of discounts and procedure groupings in the practice management system compared to the board approved fee schedule. Only one procedure group required correction of one procedure code. • In addition, the Director of Patient Revenue will work with the Electronic Health Record vendor to organize the system procedure classes for all procedure codes and financial classes to decrease any crosswalk issues or redundancies. In addition, the Director of Patient Revenue will work with the EHR vendor to upload fee schedules and sliding fee discount groups electronically. Previous internal controls adopted include: • Upon creating adding a new charge to the system, the Director of Patient Revenue posts the charge into a test patient account to confirm that the standard and slide rates match those entered on the fee schedule • At the annual review and/or revision of the Agency’s fee schedule, the Billing Manager assists the Director of Patient Revenue in reviewing every charge on the updated/approved year’s fee schedule to confirm the rates and slide assignment match the Fee Schedule. • A quarterly audit of insured and self-pay patients occur to review that adjustments are correct per agency policy. This action decreases chances of system issues that cause erroneous adjustments going unnoticed. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Debra Savoie, CFO at (860) 456-6271.
Management agrees with the finding. A separate residual receipts account will be set up and any residual receipts funds will be transferred to the new account. Management will ensure that future residual receipts are deposited into the correct account.
Management agrees with the finding. A separate residual receipts account will be set up and any residual receipts funds will be transferred to the new account. Management will ensure that future residual receipts are deposited into the correct account.
View Audit 3735 Questioned Costs: $1
Management agrees with the finding. A separate residual receipts account will be set up and any residual receipts funds will be transferred to the new account. Management will ensure that future residual receipts are deposited into the correct account.
Management agrees with the finding. A separate residual receipts account will be set up and any residual receipts funds will be transferred to the new account. Management will ensure that future residual receipts are deposited into the correct account.
View Audit 3734 Questioned Costs: $1
United States Department of Treasury Indiana Finance Authority, a Component Unit of the State of Indiana (IFA) submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Katz, Sapper & Miller, LLP 800 East 96th Street, S...
United States Department of Treasury Indiana Finance Authority, a Component Unit of the State of Indiana (IFA) submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Katz, Sapper & Miller, LLP 800 East 96th Street, Suite 500 Indianapolis, IN 46240 Audit period: Year ended June 30, 2023 The findings from the schedule of findings and questioned costs for the year ended June 30, 2023, are discussed below. The findings are numbered consistently with the numbers assigned in the Schedule. FINANCIAL STATEMENT FINDINGS None FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 2023-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Significant Deficiency in Internal Control over Compliance and Noncompliance – H. Period of Performance Recommendation: The Auditor recommended the IFA implement procedures to ensure the disbursement review process is operating effectively. Planned Corrective Actions: The Indiana Finance Authority (IFA) has procedures in place to assure the appropriate use of the federal funds the IFA manages. IFA oversight includes the robust review process of all disbursements which includes IFA engineers and finance staff. With respect to the matter your letter references, the IFA reviewed our existing Standard Operating Procedures and have edited them to reflect the date of the period of performance as part of the checklist for the program. The new IFA Program Manager has been updated on the procedures and the importance of being in compliant with the federal guidelines. The funds were corrected subsequent to year end and paid with operating revenues during fiscal year 2024. If the United States Department of Treasury has questions regarding this plan, please call Dan Huge, Public Finance Director of the State of Indiana at 317.233.4332.
View Audit 3718 Questioned Costs: $1
Common Origination and Disbursement (COD) Reporting Planned Corrective Action: We’ve created a new activity in Anthology SIS labeled “FA – Return to Title IV” to be assigned to both FA staff and Student Accounts staff when returns are needed. These activities will include detailed notes as to what r...
Common Origination and Disbursement (COD) Reporting Planned Corrective Action: We’ve created a new activity in Anthology SIS labeled “FA – Return to Title IV” to be assigned to both FA staff and Student Accounts staff when returns are needed. These activities will include detailed notes as to what returns need to be applied to posted funds on the student’s ledger. This will ensure that we apply returns as required and that the returns applied also match the applied returns in COD. FA Solutions and DCC are aligned on better communications for returns that need to be applied to ensure accuracy going forward. Person Responsible for Corrective Action Plan: Jean-Claude St Juste, Financial Aid Director, Student Accounts staff, and FA Solutions staff. Anticipated Date of Completion: Immediately
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: We are working towards MFA with SIS (Anthology), as SIS does not currently have MFA in the built-in security. We are exploring a scope of work to move to MS SSO with Anthology Support. Our hope is to finish this by the 2nd Quarter 2...
Gramm-Leach-Bliley Act (GLBA) Compliance Planned Corrective Action: We are working towards MFA with SIS (Anthology), as SIS does not currently have MFA in the built-in security. We are exploring a scope of work to move to MS SSO with Anthology Support. Our hope is to finish this by the 2nd Quarter 2024, or sooner. We are also evaluating other SIS systems and are evaluating whether those systems have SSO and MFA capabilities. Furthermore, we will review vendor contracts to include the required GLBA language and fully complete the Annual Vendor Review Checklist as specified in our Information Security Program and Incident Response Plan. We will provide an annual report to the Board of Trustees to include addressing service provider arrangements and any events or violations and management’s response to each one. We have had no breaches during the 2022-2023 and continue to monitor existing Microsoft platforms, AD Security groups, policies including MS 365 integrations, and Identity (formerly Azure) SSO integration with continual testing and reviews against potential threats. Future projects include potentially adding a Cyber security MDR on the endpoints of all DCC workstations and servers to close any gaps or potential areas of weakness, including Dark Web scans. Person Responsible for Corrective Action Plan: Stephen Cobb, Director of Technology and Christopher Winslow, VP of Finance and Operations Anticipated Date of Completion: June 2024
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Incorrect enrollment reporting was found for one student. Currently, the Registrar’s Office, in coordination with the National Student Clearinghouse, reports enrollment to NSLDS. The program for th...
Incorrect Enrollment Reporting to National Student Loan Data System (NSLDS) Planned Corrective Action: Incorrect enrollment reporting was found for one student. Currently, the Registrar’s Office, in coordination with the National Student Clearinghouse, reports enrollment to NSLDS. The program for that one student was shown incorrectly in the system for a period during the audit. When checked later, still during the audit, the program was shown correctly without any action by personnel of the college. We are unsure of the cause of this inconsistency in that instance. The Financial Aid Office will start conducting weekly spot checks directly in NSLDS to help catch enrollment that may have been reported incorrectly. The first spot check is expected to be completed the week of November 13-17. Person Responsible for Corrective Action Plan: Jean-Claude St Juste, Financial Aid Director Anticipated Date of Completion: Immediately
Return of Title IV (R2T4) Calculations Planned Corrective Action: Incorrect R2T4 calculations were found for one new student due to the wrong start date being used for the calculations. In the future, the Financial Aid Office will review R2T4s submitted for new students to ensure the new student sta...
Return of Title IV (R2T4) Calculations Planned Corrective Action: Incorrect R2T4 calculations were found for one new student due to the wrong start date being used for the calculations. In the future, the Financial Aid Office will review R2T4s submitted for new students to ensure the new student start listed in the catalog is used for the calculations irrespective of the course dates on the student’s schedule. Person Responsible for Corrective Action Plan: Jean-Claude St Juste, Financial Aid Director Anticipated Date of Completion: Immediately
The Senior Accountant responsible for this property, Corey Krajewski (krajewski@wdchoc.org) will ensure that appropriate fees will be allocated and charged.
The Senior Accountant responsible for this property, Corey Krajewski (krajewski@wdchoc.org) will ensure that appropriate fees will be allocated and charged.
View Audit 3649 Questioned Costs: $1
Return to Title IV (R2T4) Calculations (OPEID: 04278800) Planned Corrective Action: The Academic Affairs leaders, partnering with the Digital Learning Solutions team and Information Technology team, have developed a query that removes the uncertainty from the F and FN assignments and will be impleme...
Return to Title IV (R2T4) Calculations (OPEID: 04278800) Planned Corrective Action: The Academic Affairs leaders, partnering with the Digital Learning Solutions team and Information Technology team, have developed a query that removes the uncertainty from the F and FN assignments and will be implementing this in the Fall 1 2023 session. Prior to this the process was largely manual and at the discretion of individual instructors. With this query, academic administrators will be able to verify any grades that have been entered incorrectly by the instructor and ensure they are immediately changed to reflect the correct grade. Once this new process is implemented LAPU academic leaders hope to refine the process further in order to automate issuing FN grades to those who qualify, thereby preventing such mistakes in the future. Upon receipt of the report from the Digital Learning Solutions team the Financial Aid team will conduct a thorough evaluation to compare the F and FN grades against the Last Date of Attendance (LDA) to ascertain the correctness of the F or FN grade, taking into consideration the date of the last recorded academic activity. Should any disparities emerge during this evaluation, Financial Aid will initiate a request for Academics to re-examine the student’s grade for accuracy. Person Responsible for Corrective Action Plan: Dr. Wayne R. Herman, Vice President, Chief Academic Officer Anne Rodriguez, Director of Financial Aid Anticipated Date of Completion: October 27, 2023
Management will ensure the surplus cash calculation is completed in a manner that allows for a timely deposit of any required deposit to the residual receipts account.
Management will ensure the surplus cash calculation is completed in a manner that allows for a timely deposit of any required deposit to the residual receipts account.
View Audit 3632 Questioned Costs: $1
Management will implement measures to ensure the Organization will deposit “Surplus Cash” as defined by HUD, existing at the end of the fiscal year in a residual receipts account in the name of the Organization within 90 days subsequent to the end of the fiscal year. The Organization deposited $30,0...
Management will implement measures to ensure the Organization will deposit “Surplus Cash” as defined by HUD, existing at the end of the fiscal year in a residual receipts account in the name of the Organization within 90 days subsequent to the end of the fiscal year. The Organization deposited $30,051 into the residual receipts account on May 22, 2023.
View Audit 3631 Questioned Costs: $1
See corrective action plan in audit report
See corrective action plan in audit report
View Audit 3625 Questioned Costs: $1
Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreement with th...
Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A second staff person has completed the Department of Justice Grants Financial Management Training and is now qualified to work on the federal grants. This will allow the agency to have one finance person creating the reimbursement calculations and a second finance person reconciling the calculations. Name(s) of the contact person(s) responsible for corrective action: Peter Hermann.
View Audit 3565 Questioned Costs: $1
2023-002 Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreemen...
2023-002 Department of Justice Housing – Assistance Listing No. 16.320 Recommendation: We recommend reimbursement requests be reviewed and traced back to supporting documentation prior to the filing of the reimbursement request. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A second staff person has completed the Department of Justice Grants Financial Management Training and is now qualified to work on the federal grants. This will allow the agency to have someone other than that the person creating the reimbursement material to request the reimbursement. This adds an additional layer of control over the amount requested for reimbursement. Name(s) of the contact person(s) responsible for corrective action: Peter Hermann Planned completion date for corrective action plan: November 6, 2023
View Audit 3565 Questioned Costs: $1
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