Corrective Action Plans

Finding 524963 (2024-001)

Material Weakness 2024

CA

Questioned Costs Special Tests & Provisions Student Financial Aid

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and impo...

Management’s Corrective Action Plan National University acknowledges the findings and the recommendations regarding improving procedures. FINDING 2024-001 – Special Tests and Provisions – Return of Title IV: Material Weakness in Internal Control National University acknowledges the finding and importance of accurate identification and timely and accurate calculation of R2T4s. The University has made significant efforts to improve all areas of R2T4 processing, and the results of this audit show significant gains over the previous year. Given the timing of the FY 23 audit completion in February 2024 with CAP completion scheduled for June 2024, the benefits of the FY 23 corrective action plan have a limited impact on this audit period. This, coupled with the improved results the institution has seen in timeliness such as the late return error rate having decreased from 31% in FY 23 to 13% in the current audit, suggests that NU is pathing towards compliance with R2T4 requirements. Based on this assessment, NU will continue to take the following actions: • Continual assessment of staffing levels and hiring as needed to ensure timely identification and processing of R2T4s. Staffing ratios were established in FY24 and staffing increases were implemented to ensure accurate processing and timely completion. • Continual identification of risks with weekly testing and readouts from Quality Assurance to the financial aid processing team. • Re-training with the R2T4 processing team on the order of returns. • Identification and timely delivery of training for areas of risk identified in the weekly reviews. • Revise internal processes between the Quality Assurance and financial aid processing to better communicate policy and regulatory guidance in areas of identified risk/confusion during R2T4 processing. Contact Person Responsible for Corrective Action: • Rob Conlon, AVP Financial Aid Compliance • Alan Coddington, AVP Student Financial Services Anticipated Completion Date: January 2025

View Audit 344308 Questioned Costs: $1

Finding 524888 (2024-002)

Significant Deficiency 2024

Eastern Michigan University

MI

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

Condition: Of the 40 students selected for Return of Title IV (R2T4) testing, 1 student did not have the appropriate amount returned to the federal agency. Planned Corrective Action: To prevent human error from occurring in the future, the Office of Financial Aid has immediately implemented the foll...

Condition: Of the 40 students selected for Return of Title IV (R2T4) testing, 1 student did not have the appropriate amount returned to the federal agency. Planned Corrective Action: To prevent human error from occurring in the future, the Office of Financial Aid has immediately implemented the following process: When a recipient of Title IV grant or loan assistance withdraws from Eastern Michigan University and a Return of Title IV calculation is performed, a Senior Financial Aid Advisor or member of the Financial Aid Management staff will review all required returns completed to ensure accuracy. This review will occur on a weekly basis. Contact person responsible for corrective action: Jennifer Tremewan, Asst. Director Office of Financial Aid Anticipated Completion Date: December 31, 2024

View Audit 344249 Questioned Costs: $1

Finding 524881 (2024-002)

Significant Deficiency 2024

East Windsor Regional School District

NJ

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.403 § 200.430

Cross training will occur between the BA, Assistant BA and the Senior Accountant. In the event of extended vacancies or absences, multiple staff members will be trained on filing correct final reports.

View Audit 344245 Questioned Costs: $1

Finding 524859 (2024-002)

Significant Deficiency 2024

High Point University

NC

Questioned Costs Special Tests & Provisions HUD Housing Programs

Finding 2024-002 Program: Federal Work-Study Program Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2023 - 2024 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program fi...

Finding 2024-002 Program: Federal Work-Study Program Assistance Listing No.: 84.033 Federal Agency: Department of Education Award Year: FY 2023 - 2024 Compliance Requirement: N – Special Tests and Provisions – Institutions are required to verify students are not earning Federal Work-Study program financial aid during scheduled class time, and that all amounts paid are appropriately earned. University’s Response: The University continues to emphasize and reinforce with its students and student supervisors that, regardless of whether jobs are funded by the Federal Work Study program or by the institution, students must not be working during scheduled class hours regardless of whether the class is cancelled or let out early. The Student Employment Program holds annual training sessions for and provides updated publications to these responsible individuals. As part of the University student employment application process, students must submit their class schedule with their application. The University expects supervisors to utilize the student class schedules provided and keep work schedules distinct. The University also expects that supervisors continue to obtain students class schedules each semester and updates students work schedules accordingly each semester to ensure students are not working during times they are in class. The University continues to use the internal audit process it instituted in February 2023. A sample of student work records from the previous semester will be compared to students’ class schedules to ensure students are not working during class hours. This review will be performed by Michael Peeler, Vice President for Financial Affairs. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Corrective Action Plan: The University’s Student Employment Office continues to send monthly emails to student employee supervisors and to the student staff, reminding them of the student employment guidelines they are expected to abide by. This communication reminds them of their responsibility to adhere to student employment guidelines and their responsibility to keep their supervisor informed of any changes they may make to their class schedule that could require their work schedule to be adjusted. Since the hours of overpayment appeared to be resulting from students failing to clock out and managers failing to catch inaccurate hours of record (working for eight or more hours in a day, working overnight, etc.), further training and instruction to pay closer attention to these discrepancies so they are corrected at the time of approving timesheets has been provided to student employee supervisors as part of the monthly email communication. Student employee supervisors will continue to be expected to hold a mandatory meeting with their student staff at or before the start of each semester.The University’s internal audit process is also being expanded to be performed quarterly, twice each semester. This process will continue to sample student work records at the midpoint and end of the fall and spring semesters, where students’ class schedules are compared to hours worked to ensure students are not working during class hours. Michael Peeler, Vice President for Financial Affairs, will perform this review. Any violations of the school’s student employment policies identified in this audit will be reported to Marc Sears, Vice President of Human Resources, for corrective action to be taken. Name of Responsible Person: Jonathan Mador, Assistant Vice President of Student Financial Services; Sandra Fantauzzi, Student Employment Program Manager; Marc Sears, Vice President of Human Resources; Brad Calloway, Senior Vice President for Business Affairs Anticipated Completion Date: March 31, 2025

View Audit 344215 Questioned Costs: $1

Finding 524808 (2024-001)

Significant Deficiency 2024

Corban University

OR

Questioned Costs Student Financial Aid Significant Deficiency

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The academic calendar has been updated between academic catalog and website ensuring better accuracy. Policies and procedures surrounding the date of withdrawal and what constitutes an academic break have also been corrected and u...

Inaccurate Return of Title IV Funds (R2T4) Planned Corrective Action: The academic calendar has been updated between academic catalog and website ensuring better accuracy. Policies and procedures surrounding the date of withdrawal and what constitutes an academic break have also been corrected and understood across the Registrar and Financial Aid offices. Financial Aid professionals have also been added to internal meetings where decisions on programs, academic calendars, and other significant timing decisions are made to better enhance our ability to comply. Person Responsible for Corrective Action Plan: Jordan Lindsey, Vice President for Enrollment Management and Marketing Anticipated Date of Completion: 2/1/25

View Audit 344190 Questioned Costs: $1

Finding 524790 (2024-002)

Significant Deficiency 2024

University of Dubuque

IA

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking § 200.303

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and process...

Finding: The University’s R2T4 calculation was improper for one student, as the student had not signed a promissory note for the direct loans and the direct loans should have not been included in the calculation. Corrective Actions Taken or Planned: The Director of Financial Aid reviews and processes the R2T4 calculations. The Director will reassess R2T4 calculations and verify that only aid with signed promissory notes are being included in R2T4 calculations. Internal policies and procedures have been updated to ensure accurate calculations. Person Responsible: Teresa Brahm, TBrahm@dbq.edu Anticipated completion date: 09/25/2024

View Audit 344180 Questioned Costs: $1

Finding 524785 (2024-003)

Significant Deficiency 2024

Bethel University and Affiliates

MN

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

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no dis...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are completed timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On October 26, 2024, three modifications were made to the reporting tool the financial aid office uses for Return of Title IV Funds calculations to draw attention to situations when the “student completed more than 49% of a course” exception applies. First, we added a formula to the "5 - Title IV Checklist Revised" sheet in cell D16:F17. If the answer to question 11 "Exemption 3b: Successfully complete >49%?" is Yes, the following narrative will appear in blue, bold, font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Second, we modified a formula in cell J34 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, red font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." Third, we added a formula to cell E36 on the "2 - R2T4 Calc Required" sheet, so that if there is a "yes" in cell C45 (indicating the student qualifies for the "completed more than 49% of a modular course" exemption), then the following phrase will appear in bold, blue font: "Student Completed more than 49% of a modular course; Exemption 3b applies; NOT a Withdrawal. R2T4 NOT Required. Might need to recalc aid." In addition, we completed additional training with the financial aid staff who complete R2T4 calculations to ensure they (a) understand rules related to the “student completed more than 49% of a course” exception, and (b) are aware of the additional warning messages that will appear in our R2T4 calculation spreadsheet. Name of the contact person responsible for corrective action: Jeffrey D Olson, Interim Director of Financial Aid Planned completion date for corrective action plan: October 26, 2024.

View Audit 344164 Questioned Costs: $1

Finding 524775 (2024-002)

Significant Deficiency 2024

Mercyhurst University

PA

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Finding: During the course of testing return of Title IV funds, the calculation was not accurate for one student from the sample and therefore the proper amount of funds to be returned in the appropriate time required was not accurate. View of responsible officials and corrective action: Managemen...

Finding: During the course of testing return of Title IV funds, the calculation was not accurate for one student from the sample and therefore the proper amount of funds to be returned in the appropriate time required was not accurate. View of responsible officials and corrective action: Management understands the need for accurate calculation of funds to be returned. An additional step has been added to the process for the return of Title IV funds process. All calculations are now reviewed by a manager before release to ensure funds are calculated correctly and returned in the appropriate timeframe.

View Audit 344161 Questioned Costs: $1

Finding 524720 (2024-003)

Significant Deficiency 2024

Detroit Housing Commission

MI

Questioned Costs HUD Housing Programs Significant Deficiency

Condition: The Commission did not complete fiscal year 2024 recertifications. Planned Corrective Action: Annual Delinquent Recertifications are being addressed according to HUD policy. Rent Calc training has been provided and passed by all staff. We certify and maintain it will be our standard opera...

Condition: The Commission did not complete fiscal year 2024 recertifications. Planned Corrective Action: Annual Delinquent Recertifications are being addressed according to HUD policy. Rent Calc training has been provided and passed by all staff. We certify and maintain it will be our standard operating procedure to ensure compliance with HUD policies. We will continue to mitigate PIC errors and ensure continued staff training to reduce these errors. HCV Manager, will randomly review 10% of files for accuracy. A list will be maintained. As of February 17, 2025, HUD’s Recertification score was 99.7% in compliance. Contact person responsible for corrective action: Felicia Burris, HCV Program Director Anticipated Completion Date: 6/30/2025

View Audit 344146 Questioned Costs: $1

Finding 524706 (2024-002)

Significant Deficiency 2024

Housing and Redevelopment Authority of Austin

MN

Questioned Costs Cash Management Internal Control / Segregation of Duties

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Complia...

Cash Management Federal Agency: Department of Housing and Urban Development Federal Program Name: Housing Voucher Cluster Assistance Listing Number: 14.871 Award Period: October 1, 2023 – September 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Recommendation: We recommend that the HRA continue to evaluate their procedures and controls in place over the draw down of funds. Management’s Response: Management agrees with the finding and will continue to monitor the draws to ensure they are spent within the required timeframe. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will ensure that all draws of funds are spent within the required timeframe. Official Responsible for Ensuring CAP: Angela Maiden, Finance Director, is the official responsible for ensuring corrective action of the deficiency. Planned Completion Date for CAP: September 30, 2025 Plan to Monitor Completion of CAP: Taggert Medgaarden, Executive Director, will ensure that the draw downs are properly managed through discussions with the Finance Director.

View Audit 344136 Questioned Costs: $1

Finding 524679 (2024-004)

Significant Deficiency 2024

La Salle University

PA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding checks to ensure they are being returned to the Department of Education after 240 days. Explanati...

Student Financial Assistance Cluster-Assistance Listing No. 84.0007, 84.033, 84.063, 84.268 Recommendation: We recommend the University review its policies and procedures related to Title IV outstanding 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 : La Salle University will identify outstanding not cashed checks for each term. A term is normally 4 months in total as each semester generates a list of uncashed checks. Within two weeks of establishing outstanding checks, we will send letters to students informing them that they have outstanding refund checks. For approximately six months, the process of reviewing the outstanding list repeats, and if a check has not been cashed, another letter of notice is mailed. After six months, finance will send the outstanding list to Student Financial Services for a 30-day final review/outreach. At 21 O days from original refund issuance, Finance will provide the list to Financial Aid who will return balances to DOE. Name(s) of the contact person(s) responsible for corrective action: Zak Thornton, Assistant Vice President of Finance Planned completion date for corrective action plan: Corrected as of Spring 2025.

View Audit 344109 Questioned Costs: $1

Finding 524647 (2024-006)

Significant Deficiency 2024

Eureka College

IL

Questioned Costs Student Financial Aid Special Tests & Provisions

2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-006 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 4 out of the population of 6 (67%) Spring withdrawal calculations as two students had attended over 60% of the semester for bot the original and updated calculations and as such, no return was required. A sample of Fall withdrawal calculations identified no errors. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: JFA did not accurately include days of breaks for Spring Break. A manual R2T4 calculation is in place to catch errors in the days in a semester. Responsible Person: Tim Marten Implementation Date: 7/01/2024

View Audit 344088 Questioned Costs: $1

Finding 524639 (2024-003)

None 2024

Eureka College

IL

Questioned Costs Student Financial Aid Cash Management

2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-003 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b) 84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: Three of the 40 student files (7.5%) we examined, we noted the students were not properly awarded Direct loans. We consider this condition to be an instance of noncompliance relating to the Eligibility compliance and is part a repeat finding shown in Section IV of this report as prior year finding 2023-003. Management Response: Management agrees with the finding Corrective Action Plan: Loan calculations are automatic as part of JFA. Any manual changes to these loan amounts will be documented on the student file to justify differing amounts. Responsible Person: Tim Marten Implementation Date: 7/01/2024

View Audit 344088 Questioned Costs: $1

Finding 524636 (2024-001)

Significant Deficiency 2024

Eureka College

IL

Questioned Costs Student Financial Aid Cash Management

2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063...

2024-001 - Student Financial Aid Cluster - (a) Federal Pell Grant (b) Federal Supplemental Educational Opportunity Grant (c) Federal Work Study Grant (d) Federal Perkins Loan Program (e) Federal Direct Student Loans (f) Teacher education Assistance for College and Higher Education ALN No. (a) 84.063 (b)84.007 (c) 84.033 (d) 84.038 (e) 84.268 (f) 84.379 - Year Ended June 30, 2024. Condition: During our testing of thirty-seven draw downs, we noted 4 individuals (11%) that resulted in having cash on hand that exceeded the immediate disbursement need for three working days and the excess cash tolerances were not eliminated within seven working days. We consider this condition to be a significant deficiency relating to the Cash Management compliance requirement. Statistical sampling was not used in making sample selections. Management Response: Management agrees with the finding Corrective Action Plan: Implementation of a newer process based on the system and program defaults in Jenzabar Financial Aid (JFA). Will use posted dates in Sonis to ensure they match COD within the 3-day regulatory requirement. New reporting usages of SAS loan files will be checked in Sonis to ensure matching disbursement dates. Responsible Person: Tim Marten and Beth Collingwood Implementation Date: 7/01/2024

View Audit 344088 Questioned Costs: $1

Finding 524632 (2024-001)

None 2024

Bellarmine University

KY

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

Bellarmine University agrees with the auditors’ finding and recommendations. The following corrective action will be taken: The University will return $1,779 in federal student financial aid to the United States Department of Education (USED) which represents the updated R2T4 accounting for the corr...

Bellarmine University agrees with the auditors’ finding and recommendations. The following corrective action will be taken: The University will return $1,779 in federal student financial aid to the United States Department of Education (USED) which represents the updated R2T4 accounting for the correct withdrawal dates in the Spring 2024 semester. There will be an additional review process that will include validation from financial and student accounts to verify calculations before finalizing returns of funds. Financial Aid will provide an additional R2T4 form that has date of determination and LDA. Financial Aid will review that all dates and calculations match after the R2T4 has been completed and before handing off to student accounts. Student accounts will then review to confirm all dates and amounts match before processing the return of funds. April Tretter, Director of Financial Aid, expected implementation date 2.26.25.

View Audit 344071 Questioned Costs: $1

Finding 524630 (2024-004)

Significant Deficiency 2024

Keystone College

PA

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

Management will implement a thorough review process of calculations to ensure proper dates are being used. Additionally, management will review update routines and communication of student enrollment status to ensure timely cacluation and return of any unearned portion of grant or loan funds to the...

Management will implement a thorough review process of calculations to ensure proper dates are being used. Additionally, management will review update routines and communication of student enrollment status to ensure timely cacluation and return of any unearned portion of grant or loan funds to the appropriate Title IV program in accordance with federal regulations.

View Audit 344059 Questioned Costs: $1

Finding 524629 (2024-003)

Significant Deficiency 2024

Keystone College

PA

Questioned Costs Subrecipient Monitoring Cash Management

Management will review the FY 24 FISAP report concerning the accuracy of the SEOG drawdown and whether any portion of the drawdown should have been reported as carryover funds. Any overdraw determined as part of this reconciliation will be returned to the U.S. Department of Education. The College ...

Management will review the FY 24 FISAP report concerning the accuracy of the SEOG drawdown and whether any portion of the drawdown should have been reported as carryover funds. Any overdraw determined as part of this reconciliation will be returned to the U.S. Department of Education. The College has also strengthened controls and trained staff to ensure compliance with cash management practices for future federal awards.

View Audit 344059 Questioned Costs: $1

Finding 524561 (2024-007)

Material Weakness 2024

Santa Rosa Consolidated Schools

NM

Questioned Costs

The business office will create a document to help determine the worker's relationship status and incorporate it into the process before issuing purchase orders. Additionly, the business office will review all independent contractors providing services to the district to ensure compliance.

View Audit 343991 Questioned Costs: $1

Finding 524550 (2024-001)

Significant Deficiency 2024

Des Moines Rhf Housing, Inc. Dba Virginia Park Apartments #074-Eh184

CA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Statement of Condition 2024-001 (Assistance Listing 14.181): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended October 31, 2024. Recommendation: Management should transfer $19,200 from the operating cash account to the reserve for replacements ...

Statement of Condition 2024-001 (Assistance Listing 14.181): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended October 31, 2024. Recommendation: Management should transfer $19,200 from the operating cash account to the reserve for replacements fund or request a suspension of monthly deposits from HUD. Management Response: Agree. On January 9, 2025, management transferred $19,200 from the operating account to the reserve for replacements fund.

View Audit 343963 Questioned Costs: $1

Finding 524545 (2024-004)

Significant Deficiency 2024

Lawton Independent School District No. 8

OK

Questioned Costs Equipment & Real Property Management Procurement, Suspension & Debarment

Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools did not correctly track the distribution of devices by source of funding. The 700 devices were distributed along with other like-devices. More than 700 devices were originally distributed to the “approved populati...

Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools did not correctly track the distribution of devices by source of funding. The 700 devices were distributed along with other like-devices. More than 700 devices were originally distributed to the “approved population” but not necessarily the 700 devices listed as purchased by the funds. Since the initial distribution, Lawton Public Schools has implemented software tracking of devices that includes the current location and disposition of these devices.

View Audit 343953 Questioned Costs: $1

Finding 524509 (2024-001)

Significant Deficiency 2024

Cornish College of the Arts and Cornish Foundation

WA

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College 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 a...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend that the College 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: The College has reviewed and updated its procedures related to the process of reviewing and remitting unclaimed student refund checks. Name(s) of the contact person(s) responsible for corrective action: Cheryl Wynne, Interim CFO Planned completion date for corrective action plan: January 31, 2025

View Audit 343891 Questioned Costs: $1

Finding 524447 (2024-001)

Significant Deficiency 2024

National 4-H Council

DC

Questioned Costs Subrecipient Monitoring § 200.1 § 200.211 § 200.303 § 200.332

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial managemen...

MANAGEMENT’S CORRECTIVE ACTION PLAN 2 CFR § 200.511(c) June 30, 2024 Finding Number: 2024-001 – Internal Control over Compliance and Compliance with Period of Performance Planned Corrective Action: The errors identified took place during September 2023, during a period when the financial management of Council’s grants, including subrecipient monitoring and allowable cost review, were under the purview of the program teams. In May 2024, these responsibilities were deemed to be more appropriately aligned with the Finance and Business Operations Team’s skill sets and brought under that team’s management. Additionally, in December 2023, the accounts payable process was automated, enabling a more thorough review of each reimbursement package. Anticipated Completion Date: May 6, 2024 Responsible Contact Person: Stan Harrell, Chief Financial Officer

View Audit 343772 Questioned Costs: $1

Finding 524441 (2024-001)

Significant Deficiency 2024

McDaniel College and Subsidiary

MD

Questioned Costs Student Financial Aid Subrecipient Monitoring

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Y...

Finding 2024-001 Condition Finding 2024-001 – Significant Deficiency – Return of Title IV Federal Program – Federal Pell Grant Program, Federal Direct Student Loan Program Federal Agency – U.S. Department of Education Pass- Through Entity – Not Applicable ALN Number – 84.063, 84.268 Federal Award Year – May 31, 2024 Criteria: The Uniform Guidance requires recipients of federal awards to administer its federal programs with an adequate system of internal controls over applicable compliance requirements. In addition, when a recipient of Title IV grant or loan assistance withdraws from an institution during a payment period, Title IV regulations (34 CFR 668.22) require the College to determine, through a Return of Title IV Funds (R2T4) calculation, the amount of Title IV grant or loan assistance that the student earned as of the withdrawal date and return the unearned portion of the grant or loan to the Title IV programs as soon as possible but no later than 45 days after the withdrawal date. Corrective Action Plan Corrective Action Planned: {The College agrees with the finding and has taken immediate corrective action to address the finding related to R2T4 calculations. All R2T4 calculations for the related period have been recalculated and reviewed for accuracy. Any noted discrepancies related to the necessary return of funds have been addressed. Enhanced internal controls have been implemented to ensure that the dates entered in the Colleague system aligns with the academic calendar. The College will also institute an internal audit/compliance process for additional verification and monitoring. Identify the specific actions to be taken to eliminate or mitigate the recurrence of the finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Kemia Himon, Financial Aid Director Anticipated Completion Date: 3.3.25

View Audit 343760 Questioned Costs: $1

Finding 524392 (2024-001)

Material Weakness 2024

Loma Linda University

CA

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

Finding 2024-001 – Internal control deficiency and noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles related to payroll expenditures Connecting Minority Communities Pilot Program – Accuracy During testing over the Activities Allowed or Unallowed and Allowable C...

Finding 2024-001 – Internal control deficiency and noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles related to payroll expenditures Connecting Minority Communities Pilot Program – Accuracy During testing over the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirement, management did not have effective internal controls in place to ensure salaries, fringe benefits, and indirect costs were correctly allocated to the Federal award. Management Response and Action Plan: Management has adjusted for the incorrect allocation with the grantor (i.e., refunded the questioned costs) and will implement an additional review control of the allocation and final calculation of salaries, fringe benefits, and indirect costs. Responsible Person: Executive Director of Sponsored Project Administration Target Date: February 2025

View Audit 343628 Questioned Costs: $1

Finding 524388 (2024-001)

Significant Deficiency 2024

Board of Education of Prince George's County Maryland

MD

Questioned Costs Reporting § 200.502

Prince George's County Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number...

Prince George's County Public Schools respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: June 30, 2024 The 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—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of EducationStudent Support and Academic Enrichment Program– Assistance Listing No. 84.424 We recommend that the School system review its procedures to ensure that amounts reported on the SEFA are in accordance with 2 CFR part 200.502 and 510. Explanation of disagreement with audit finding: We agree with the finding in part. As the auditors noted, Grant Number 20157201, ended on 9/30/22. There were additional FY23 invoices and payroll processed to this grant after the grant was closed out by the Grant Accountant. The corrections to remove these expenses, though they caused a net effect of zero, were recorded in fiscal year 2024. The adjustments for $27,799 were mistakenly reported on the fiscal year 2024 SEFA. These additional amounts were never reported in the MSDE AFR system, because as noted, they resulted in net zero change. Reporting in the MSDE AFR system is always done with a report from Oracle, the school system’s financial reporting system, and only actual expenses are reported. In addition, at year end, the full report is reconciled to our Grants Roll Forward Report, which allows us to ensure the correct information is reported for each grant. Action taken in response to finding: The $27,799 will be removed from the FY24 SEFA. In an ongoing effort to ensure that all grants are reported correctly and in line Grant’s Administrator will hold regular meetings (at least quarterly) with the Budget Analyst and/or Grants Accountant assigned to these grant funds. The Grants Accountant will also provide transaction and payroll detail reports to the Grants Administrator on a regular basis for review and correction when necessary. Planned completion date for corrective action plan: March 2025 Contact person(s) responsible for corrective action: Department of the Division of Student Services: Elizabeth Faison, Associate Superintendent of Student Services, Ph.D., NCC, LCPC Grant Financial Management Office: Darrell Haley, Supervising Budget Analyst Claire Taylor, Supervising Grants Accountant, CPA, CGFM, CGMS

View Audit 343626 Questioned Costs: $1

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