Corrective Action Plans

Finding 15932 (2022-001)

Significant Deficiency 2022

MO

Questioned Costs Eligibility Significant Deficiency

Type of Finding: Significant Deficiency in Internal Control Over Compliance ? Eligibility Recommendation: The Organization should ensure that controls exist to document and provide evidence of review procedure in effect to ensure that eligibility requirements are met beyond the initial inquiries an...

Type of Finding: Significant Deficiency in Internal Control Over Compliance ? Eligibility Recommendation: The Organization should ensure that controls exist to document and provide evidence of review procedure in effect to ensure that eligibility requirements are met beyond the initial inquiries and information gathering process. Views of Responsible Officials: There is no disagreement with the audit finding. Eligibility requirements are obtained and documented based on the requirements of the individual grants. The program staff are well versed in the requirements and ensure the participants are eligible under the grant. In August 2021, to enhance the existing practice, a Case Management system was implemented which assists in ensuring that proper documentation and approval are maintained. In September 2023, the case management system was looked over and rules were put into place to minimize or eliminate room for human error.

View Audit 19762

Finding 15931 (2022-005)

Significant Deficiency 2022

South Carolina State Housing Finance and Development Authority

SC

Questioned Costs Reporting Significant Deficiency

COVID-19 Emergency Rental Assistance ? Assistance Listing Number 21.023 Recommendation: We recommend the Authority implements controls to ensure that documentation is maintained to support amounts reported. Review and approval of the amounts reported to Treasury should be documented. Explanation of ...

COVID-19 Emergency Rental Assistance ? Assistance Listing Number 21.023 Recommendation: We recommend the Authority implements controls to ensure that documentation is maintained to support amounts reported. Review and approval of the amounts reported to Treasury should be documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SC Housing has expended the majority of the COVID-19 Emergency Rental Assistance funds, and the program will be ending in the coming months. The close-out plan includes the transfer and archive of all data from the third-party vendor working to implement the program. A protocol was implemented with the closeout report to Treasury for ERA1 funds in January, 2023, to retain all documentation supporting the report, and all reports moving forward, in SC Housing program files. Review of future reports by the Division Director prior to submission to Treasury will be added to the reporting process. Names of the contact persons responsible for corrective action: Amanda Colbert, Marni Holloway Planned completion date for corrective action plan: partially implemented, review will begin with next report due in April, 2023.

View Audit 19599

Finding 15918 (2022-004)

Significant Deficiency 2022

South Carolina State Housing Finance and Development Authority

SC

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that rent reasonableness is determined prior to the effective date of the change in rent. Explanation of disagreement with audit finding: There is no disagreeme...

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that rent reasonableness is determined prior to the effective date of the change in rent. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional training is being provided to HCP staff to insure they have a clear understanding of the rent reasonableness requirements and timing imposed by HUD. Financing Housing. Building SC. Processes have been updated to require dual authentication. Within 10 business days of receiving a request from the owner for a rent increase, or; within 10 business days of receipt of a decrease request received from HUD, or; when there has been a 10% decrease in the fair market rent that goes into effect at least 60 days before the contract anniversary date, the Housing Program Coordinator (HPC) will make a rent reasonableness determination and approve a corresponding rent adjustment when applicable. Following assessment and action determination, all files will be reviewed a second time by a Housing Administration Coordinator for accuracy and appropriateness. Both the HPC and the Administration Coordinator will be required to acknowledge the request/action taken in writing. Late actions must be justified and reviewed by the Director of Rental Assistance and Compliance prior to effecting the change and/or issuing correspondence. Memo records will be recorded on each voucher file to document actions taken. Names of the contact persons responsible for corrective action: Yolanda Dennison, Kristel Walker, Lenzy Morris, Corrie Temples Planned completion date for corrective action plan: Partially implemented; to be finalized by June 30, 2023.

View Audit 19599

Finding 15917 (2022-003)

Significant Deficiency 2022

South Carolina State Housing Finance and Development Authority

SC

Questioned Costs HUD Housing Programs Significant Deficiency

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend that the Authority sets up a separate interestbearing account and executes a depository agreement with their financial institution and HUD; alternatively, we recommend that the Authority obtains a waiver ...

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend that the Authority sets up a separate interestbearing account and executes a depository agreement with their financial institution and HUD; alternatively, we recommend that the Authority obtains a waiver from this requirement if local regulation prohibits the Authority from following 24 CFR section 982.156. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Housing Voucher Cluster funds are held by the Treasurer for the State of South Carolina. The depository agreements in place are between the depository institution and the state Treasurer. SC Housing has contacted HUD via email and requested a waiver for this regulatory requirement. An update will be provided when available. Name of the contact person responsible for corrective action: Lisa Wilkerson Planned completion date for corrective action plan: Waiver request submitted to HUD local field office on March 29, 2023.

View Audit 19599

Finding 15916 (2022-002)

Material Weakness 2022

South Carolina State Housing Finance and Development Authority

SC

Questioned Costs Material Weakness Internal Control / Segregation of Duties

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements c...

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend the Authority implements controls to ensure that the Authority requires HQS deficiencies to be corrected within the timeframe set forth by 2 CFR section 982.404(a). We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Processes have been updated to assure that Yardi system generated letters are being utilized by staff for inspection deficiency correspondence. The vendor, Yardi, assumes responsibility for assuring that this correspondence meets all current regulatory requirements, as may be amended periodically. This will cure the notice deficiencies observed by the audit team. Additional training is being provided to HCP staff to insure they have a clear understanding of communication requirements and the critical timeline that accompanies the mitigation of exigent health and safety findings, other non-life threating deficiencies, as well as the follow-up inspection time frames allowed by HUD. Processes have been updated to require a monthly report of failed HQS inspections, to include all actions taken, be issued to the Director of Housing Choice Voucher and the Director of Rental Assistance and Compliance. This report is due by the first business day monthly and will be reviewed by senior management to determine abatements required and to issue authorization to abate within the HUD required timeframe. Memo records will be recorded on each voucher file to document actions taken. Financing Housing. Building SC. Names of the contact persons responsible for corrective action: Yolanda Dennison and Lisa Wilkerson Planned completion date for corrective action plan: Partially implemented; to be finalized by June 30, 2023.

View Audit 19599 Questioned Costs: $1

Finding 15915 (2022-001)

Material Weakness 2022

South Carolina State Housing Finance and Development Authority

SC

Questioned Costs Material Weakness Internal Control / Segregation of Duties

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend the Authority implement controls to ensure that required HQS and QC inspections are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actio...

Housing Voucher Cluster ? Assistance Listing Numbers 14.871/14.879 Recommendation: We recommend the Authority implement controls to ensure that required HQS and QC inspections are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Periodic HQS Inspections: Procedures are in place that require staff to generate a listing of all properties requiring inspection no less than one hundred twenty (120) days prior to the scheduled inspection date. Each unit under HAP contract must be inspected prior to execution of the initial lease and prior to execution of the HAP contract and no less than biennially thereafter to confirm the unit continues to meet minimum HUD requirements. Management identified a system generated report from YARDI to establish when recurring inspections must be completed. This report is generated a minimum of once monthly to assist with scheduling. The report is monitored by the Operations Manager and the Housing Choice Voucher Director. Procedures have been updated to require that the Director of Rental Assistance and Compliance review all inspections completed after the date due and the accompanying explanation for the delay. Management will track and analyze the data generated from the late inspections to identify patterns and implement corrective actions as warranted. Financing Housing. Building SC. QC Inspections: Upon discovery, a supervisor was assigned and all prior year HQS QC inspections were completed, albeit late. Effective April 1, 2023, and every month thereafter, the designated manager will conduct QC inspections utilizing the minimum file size sample based on the number of units under HAP contract annually. All required inspections will be completed no later than the end of each fiscal year. A status report documenting all efforts and results will be submitted monthly to the Director of Rental Assistance and Compliance. Management will track and analyze the data generated from these inspections to assure all program inspections are consistent and compliant and that any patterns identified are effectively addressed with additional training, etc. as warranted. Names of the contact persons responsible for corrective action: Lenzy Morris, Yolanda Dennison, Lisa Wilkerson Planned completion date for corrective action plan: June 30, 2023

View Audit 19599

Finding 15911 (2022-005)

None 2022

West Carroll Community School District No 314

IL

Questioned Costs

Changes in bookkeeping personnel contributed to this error. Benefits were included and not all evidence of costs submitted to auditing on time. Going forward, increase knowledge and awareness of district bookkeeper regarding grant details and covered items so ineligible expenses are not included in ...

Changes in bookkeeping personnel contributed to this error. Benefits were included and not all evidence of costs submitted to auditing on time. Going forward, increase knowledge and awareness of district bookkeeper regarding grant details and covered items so ineligible expenses are not included in expenditure report totals. Additional documentation can be provided upon request. See full Corrective Action Plan on the District letterhead.

View Audit 19552 Questioned Costs: $1

Finding 15909 (2022-006)

None 2022

West Carroll Community School District No 314

IL

Questioned Costs

The district did incur the expenses reported for speech therapy service; however, not all evidence of cost submitted to auditing on time showing the portion of payment for outplaced students utilizing speech therapy services. Bookkeeper will include thorough documentation of all expenses claimed wit...

The district did incur the expenses reported for speech therapy service; however, not all evidence of cost submitted to auditing on time showing the portion of payment for outplaced students utilizing speech therapy services. Bookkeeper will include thorough documentation of all expenses claimed with grant files going forward. Additional documentation can be provided upon request. See Full Corrective Action Plan on the District letterhead.

View Audit 19552 Questioned Costs: $1

Finding 15908 (2022-004)

None 2022

West Carroll Community School District No 314

IL

Questioned Costs

The District did incur the expenditures reported, however the salary obligations paid out in July and August of 2022 were reported as expenditures through June 30, 2022. Changes in bookkeeping personnel contributed to this error. In the future expenditure reports which include salary obligations yet...

The District did incur the expenditures reported, however the salary obligations paid out in July and August of 2022 were reported as expenditures through June 30, 2022. Changes in bookkeeping personnel contributed to this error. In the future expenditure reports which include salary obligations yet to be paid after June 30th will be recorded as outstanding obligations on the June 30th report with final expenditure report to be submitted by September 20th of the following fiscal year. Additional documentation can be provided upon request. See full Corrective Action Plan on the District letterhead.

View Audit 19552 Questioned Costs: $1

Finding 15899 (2022-001)

Material Weakness 2022

Woodland School District No. 404

WA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, procurement, and restricted purpose requirements. Name, address, and telephone of District contact person: Stacy Brown, Director...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, procurement, and restricted purpose requirements. Name, address, and telephone of District contact person: Stacy Brown, Director of Business Services 800 Second St Woodland, WA 98674-8467 (360) 841-2715 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The district disagrees with some portions of the finding. The district originally was not going to participate in the ECF program as we did not believe we had an unmet need, per the original requirements. We then received notification from our contractor that the FCC had clarified the rules and if we have a policy that shows we only allow district owned and managed devices on our network and we can estimate how many devices (staff and student) would be needed if the school or some schools went back to remote learning, we would qualify for funding. Based on this information and a review of our policies, we decided to apply for the funds. The finding states that we do not have internal controls in place to ensure we have all required elements for our inventories. We were not able to get serial numbers from the vendor but we were able to back into the dates the Chromebooks were entered into inventory and accounted for all 600 student devices and the students to which they were assigned. This also showed that we met the restricted purpose of one device per student or staff member. In response to the finding, the district will make the following corrective actions: 1. The Business Manager will be more diligent in ensuring that all Federal program funds are properly included on the Schedule of Expenditures of Federal Assistance (SEFA). 2. The district will ensure that they are aware of compliance requirements new or unfamiliar Federal grants. 3. The district will ensure that devices or equipment purchased with Federal funds are identified as such and accounted for as such in the district inventory. 4. The district will ensure that Federal and District procurement policies are followed, including sealed bids for purchases greater than $75.000. 5. Once accounting for ECF purchases as federal devices, the district will be able to show that only one device has been issued to each student and staff member. Anticipated date to complete the corrective action: 6/12/23

View Audit 19549 Questioned Costs: $1

Finding 15895 (2022-001)

Significant Deficiency 2022

Community College District of St. Louis

MO

Special Tests & Provisions Questioned Costs Student Financial Aid

U.S. Department of Education Community College District of St. Louis respectfully submits the following corrective action plan for the year ended June 30, 2022. Contact information for the individual responsible for the corrective action: Mark Swadener, Vice Chancellor of Finance Community College D...

U.S. Department of Education Community College District of St. Louis respectfully submits the following corrective action plan for the year ended June 30, 2022. Contact information for the individual responsible for the corrective action: Mark Swadener, Vice Chancellor of Finance Community College District of St. Louis 3221 McKelvey Road Bridgeton, MO 63044 Independent public accounting firm: KPM CPAs, PC, 1445 East Republic Road, Springfield, MO 65804 Audit Period: Year ended June 30, 2022 The finding from the June 30, 2022 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered with the number assigned in the schedule. Finding ? Major Federal Award Program Audit 2022-001 Recommendation: We recommend the College implement procedures in order to strictly comply with the requirements of 34 CFR 682.610 and 685.309 as it relates to reporting required to the NSLDS. We further recommend that the College follow the guidance provided in the NSLDS Enrollment Reporting Guide and stay abreast of new guidance as published by the Department of Education. Corrective Action Taken: The Office of the Registrar at Saint Louis Community College investigated he exception and updated our existing reporting procedures beginning with the Fall 2022 semester. The College believes the new procedures will timely identify and report the required enrollment status changes for the National Student Loan Database System (NSLDS). Anticipated Completion Date: Fall 2022 semester

View Audit 19548

Finding 15893 (2022-001)

Material Weakness 2022

Home Share 092-Hd017

MN

Internal Control / Segregation of Duties Eligibility HUD Housing Programs § 200.303

March 27, 2023 HOME SHARE HUD PROJECT NO. 092-HD017 Corrective Action Plan Finding: 2022-001 ? Compliance and Controls over Compliance ? Eligibility Supportive Housing for Persons with Disabilities (Section 811), CFDA No. 14.181 Material Weakness & Noncompliance In 2022, Home Share did not have cont...

March 27, 2023 HOME SHARE HUD PROJECT NO. 092-HD017 Corrective Action Plan Finding: 2022-001 ? Compliance and Controls over Compliance ? Eligibility Supportive Housing for Persons with Disabilities (Section 811), CFDA No. 14.181 Material Weakness & Noncompliance In 2022, Home Share did not have controls in place to ensure that eligibility criteria and rent calculations were being reviewed and/or approved by someone other than the individual making the initial determination or annual recertification. Actions Taken or Planned: Management agrees with this finding. Beginning in January 2022, management has contracted out the eligibility determination process to a third-party contractor with significant experience in affordable housing and similar processes. Management is working with the contractor to include a second individual in this process so that there will be a review performed by someone other than the individual making the initial determination or annual recertification. Contact Persons: Ernest Johnson, Housing Associate Director Robert Pickering, Chief Financial Officer

View Audit 19545

Finding 15892 (2022-001)

Material Weakness 2022

Greenwood Charter School

UT

Questioned Costs Material Weakness Reporting

Finding 2022-001 Finding Summary: Greenwood Charter School is required to submit annual financial statements and the proposed budget to the USDA. These items were not provided to the USDA by June 30, 2022. Responsible Individuals: Tracey Nelsen, Director and Matt Lovell, Business Manager Corrective ...

Finding 2022-001 Finding Summary: Greenwood Charter School is required to submit annual financial statements and the proposed budget to the USDA. These items were not provided to the USDA by June 30, 2022. Responsible Individuals: Tracey Nelsen, Director and Matt Lovell, Business Manager Corrective Action Plan: Management will provide a copy of the audited financial statements and copy of the proposed budget to USDA annually. Anticipated Completion Date: Ongoing Anticipated Completion Date: Management has provided the audited financial statements and a copy of the proposed budget to USDA in December 2022 and will continue to ensure all necessary corrective action plan items are submitted to the USDA each year.

View Audit 19543

Finding 15889 (2022-004)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

? Finding 2022-004 ? In October 2022, Management enhanced its maintained supporting documentation to provide evidence of review and approval of FEMA expenditures and financial reporting for future FEMA submissions. o Responsible Party: Amanda Zentefis

View Audit 19521

Finding 15888 (2022-005)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Reporting Questioned Costs Matching / Level of Effort / Earmarking § 200.303

? Finding 2022-005 ? On or before September 30, 2023, Management will enhance its maintained documentation to support its lost revenue calculations by NPSR by payer to support amounts submitted on the HRSA PRF portal during fiscal year 2023. In addition, Management will review all HRSA PRF portal s...

? Finding 2022-005 ? On or before September 30, 2023, Management will enhance its maintained documentation to support its lost revenue calculations by NPSR by payer to support amounts submitted on the HRSA PRF portal during fiscal year 2023. In addition, Management will review all HRSA PRF portal submissions of lost revenues covering its fiscal year 2023 and ensure evidence of review and approval of the submissions are present to evidence the presence of adherence to its internal controls. o Responsible Party: Amanda Zentefis

View Audit 19521

Finding 15884 (2022-003)

Significant Deficiency 2022

Memorial Health and Subsidiaries

IL

Subrecipient Monitoring Questioned Costs Reporting § 200.303

? Finding 2022-003 ? On or before September 30, 2023, Management will re-review its subrecipient monitoring policy and ensure it has fully complied during its fiscal year 2023. o Responsible Party: Peggy Wisher

View Audit 19521

Finding 15883 (2022-002)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Reporting Questioned Costs Allowable Costs / Cost Principles § 200.303

? Finding 2022-002 ? On or before September 30, 2023, Management will review all time & effort reporting covering its fiscal year 2023 and implement updates to its certification reporting to ensure calculations are accurately derived and verified through independent review for 100% of each employee?...

? Finding 2022-002 ? On or before September 30, 2023, Management will review all time & effort reporting covering its fiscal year 2023 and implement updates to its certification reporting to ensure calculations are accurately derived and verified through independent review for 100% of each employee?s time and effort and ensure amounts charged to the grant in fiscal year 2023 are supported by these certified records. o Responsible Party: Peggy Wisher

View Audit 19521 Questioned Costs: $1

Finding 15882 (2022-001)

Material Weakness 2022

Memorial Health and Subsidiaries

IL

Subrecipient Monitoring Reporting Questioned Costs § 200.303

? Finding 2022-001 ? In June 2023, Management re-educated itself on the terms & conditions of the Hospital Rate Agreement and has adjusted its subaward calculation forms to ensure direct costs included in the base is limited to $25,000 per subaward per grant year for purposes of calculating indirect...

? Finding 2022-001 ? In June 2023, Management re-educated itself on the terms & conditions of the Hospital Rate Agreement and has adjusted its subaward calculation forms to ensure direct costs included in the base is limited to $25,000 per subaward per grant year for purposes of calculating indirect costs. On or before September 30, 2023, Management will review all indirect cost rate calculations covering its fiscal year 2023 and ensure the correct indirect cost rate used was based on the applicable Hospital Rate Agreement. In addition, effective June 2023, Management has changed its process to ensure updates to the indirect cost rate used is applied in the month the updated Hospital Rate Agreement is received from the Federal agency, and no later. o Responsible Party: Peggy Wisher

View Audit 19521 Questioned Costs: $1

Finding 15880 (2022-001)

Significant Deficiency 2022

Mar Vista Eldorado, INC

IN

Subrecipient Monitoring Cash Management HUD Housing Programs

Name of auditee: Mar Vista Eldorado, Inc. HUD auditee identification number: 122-EH528-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2022 CAP prepared by Name: Dwight Hargett Position: President/CEO - Management Agent Tele...

Name of auditee: Mar Vista Eldorado, Inc. HUD auditee identification number: 122-EH528-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2022 CAP prepared by Name: Dwight Hargett Position: President/CEO - Management Agent Telephone number: 812-987-8344 Current Findings on the Summary of Auditors Results Statement of Condition 2022-001 (Assistance Listing Number 14.157): The required residual receipts deposit in the amount of $9,607 per the June 30, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited into the residual receipts account within 90 days after the fiscal year end. Recommendation: Management should make a deposit of $9,607 to the residual receipts account for the underfunded amount. Additionally, management should make deposits, as required by the Regulatory Agreement, on an annual basis. Actions taken or planned on the finding: Management made a deposit of $9,607 on August 4, 2022 to fully fund the residual receipts account for the year ended June 30, 2022.

View Audit 19417 Questioned Costs: $1

Finding 15875 (2022-007)

Material Weakness 2022

School District of Marathon City

WI

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Child Nutrition Cluster Reporting Child Nutrition Cluster - Assistance Listing No. 10.553, 10.555 Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure accounts agree back to supporting doc...

Child Nutrition Cluster Reporting Child Nutrition Cluster - Assistance Listing No. 10.553, 10.555 Recommendation: We recommend the District implement a review procedure over reimbursement requests where someone other than the preparer reviews the claim to ensure accounts agree back to supporting documentation prior to the reimbursement request being filed with the grating agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action Planned/Taken: Food service reports are now reviewed and initialed monthly. Food service director would initially run the report and it would be reconciled by the Business Manager. Final claims are reconciled before the report is submitted and initialed by the Superintendent. Name(s) of the contact person(s) responsible for corrective action: Nimisha Patel, Business Manager Planned completion date for corrective action plan: January 1, 2023

View Audit 19352

Finding 15873 (2022-002)

None 2022

Cleveland Supported Housing INC

TX

Questioned Costs Reporting Internal Control / Segregation of Duties

Audit Finding 2022-02: There was a shortfall in the monthly deposits to the replacement reserve due to the December 2022 deposit not being made in a timely manner. We have made up the shortfall in January 2023 and in the future, will ensure the monthly deposits are done in a timely manner.

View Audit 19237

Finding 15872 (2022-001)

None 2022

Cleveland Supported Housing INC

TX

Questioned Costs Reporting Internal Control / Segregation of Duties

Audit Finding 2022-01: Some invoices were duplicated on requests for withdrawal from the replacement reserve. Hence, funds were withdrawn for expenditures which had been included in other requests for withdrawal. We are reviewing our process for requesting withdrawals from the replacement reserve to...

Audit Finding 2022-01: Some invoices were duplicated on requests for withdrawal from the replacement reserve. Hence, funds were withdrawn for expenditures which had been included in other requests for withdrawal. We are reviewing our process for requesting withdrawals from the replacement reserve to ensure there is no duplication of expenditure claimed in the future. We will reimburse the reserve for replacement for the overdrawn funds as soon as possible.

View Audit 19237 Questioned Costs: $1

Finding 15869 (2022-002)

None 2022

Simmons University

MA

Questioned Costs Student Financial Aid Reporting

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened...

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened prior to FY22 with the full launch in production taking place for the Fall 2021. Understandably, some of the integrations of these two systems were not able to be tested prior to Fall of 2021 (ex: actual disbursement of federal loans) and therefore, required significant time and effort in the Fall and beyond to ensure everything worked and students were able to receive funding while also building out and documenting required communications, processes, and compliance protocols. Additionally, we had turnover within the Associate Director of Financial Aid and Loan Manager role in March 2022. The implementation coupled with this staffing issue created a one-time set of circumstances that are outside of the standard oversight and management of our Federal Student Aid funds and processes. Please refer to the response to each individual finding as follows: Finding 2022-002: Borrower data and reconciliation reporting Award Information Cluster: Student Financial Assistance Agency: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 As mentioned above, the University implemented two brand new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. During the first month of the Fall term there were significant challenges with the communication between these systems, which resulted in our first group of loans being disbursed in the last few days of September 29, 2021. It is a known issue that any loans that disburse at the end of the month are not included in the Federal SAS Reconciliation file and as a result this disbursement resulted in significant errors. Ultimately, the University was not able to finalize this reconciliation for this month. As mentioned above, the Financial Aid Office was restructured to provide even greater oversight over our Federal funds. Under the restructured office, the new Associate Director and Manager of Loans and Pell Grants has documented all processes, including reconciliation. Additionally, we created an automated report that is generated after the SAS is received and loaded into PowerFaids. A notification is sent to both the Associate Director/Loan Manager as well as the Director of Financial Aid Systems, Reporting and Compliance to provide documentation that the report was run. The Loan Manager reports to the Director of Financial Aid Systems, Reporting and Compliance who signs the completed SAS reconciliations. This process was fully put into place, including signature, for the 2022-2023 academic year beginning with the September 2022 Reconciliation. The Director of Financial Aid Systems, Reporting and Compliance, Amanda Galban, who can be reached at amanda.galban@simmons.edu, is responsible for the implementation of this corrective action plan.

View Audit 19033

Finding 15868 (2022-001)

None 2022

Simmons University

MA

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

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened...

Management?s Views and Corrective Action Plan The University implemented two new systems (Student Information System ? Workday, and Financial Aid System ? PowerFaids) that each are an important part of managing our Federal Student Aid. Most of the building and configuring of these systems happened prior to FY22 with the full launch in production taking place for the Fall 2021. Understandably, some of the integrations of these two systems were not able to be tested prior to Fall of 2021 (ex: actual disbursement of federal loans) and therefore, required significant time and effort in the Fall and beyond to ensure everything worked and students were able to receive funding while also building out and documenting required communications, processes, and compliance protocols. Additionally, we had turnover within the Associate Director of Financial Aid and Loan Manager role in March 2022. The implementation coupled with this staffing issue created a one-time set of circumstances that are outside of the standard oversight and management of our Federal Student Aid funds and processes. Please refer to the response to each individual finding as follows: Finding 2022-001: Returns of Title IV Funds Award Information Cluster: Student Financial Assistance Cluster Grantor: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2021 ? June 30, 2022 Assistance Listing Number: 84.268 In implementing PowerFaids we were required to set up our own Selection Sets (set group of criteria) for managing all of the disbursements (positive or negative) for each type of fund. For all of our loan funds, we used criteria that included requiring that the particular term have at least half-time enrollment. We used this selection set to disburse (increase or decrease) both the loan to the Student Account (in Workday) as well as to get on the Books with FSA (through COD). We realized that students who took a Leave of Absence or Withdrew from the University needed their own selection set because they would have been updated to have zero credits in the term they took a leave or withdrew. The two instances where we were late in adjustment, we were in the middle of the staffing situation. Documentation had not been written by the Loan Manager at that time. Once we identified the issue with the selection set for students who were withdrawn or on a leave of absence, we reviewed all students with this condition, corrected refunds as appropriate and ensured this was corrected moving forward. The Director of Financial Aid saw a need to have greater oversight on our Federal Funds. She began a process of restructuring the Office as of February 21, 2022 so that the Loan Manager position no longer had direct reports and their main responsibility is the management of federal and private loan portfolios and the federal Pell grant fund. Processes have been documented and all selection sets and processes are managed by this new Associate Director (Loan Manager) who now reports directly to the newly created Director of Financial Aid Systems, Reporting and Compliance April 21, 2022. We do not foresee further issues with return of funds within the required 45-day timeline. The Assistant Vice President, Enrollment Student Services & Director of Financial Aid, Amy Staffier, who can be reached at amy.staffier@simmons.edu, is responsible for the implementation of this corrective action plan.

View Audit 19033

Finding 15866 (2022-003)

Significant Deficiency 2022

Walhalla Community Hospital Association

ND

Questioned Costs Special Tests & Provisions Significant Deficiency § 200.303

Finding 2022-03 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 performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Debra F...

Finding 2022-03 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 performed over reconciliations of the USDA program reserve fund. Responsible Individuals: Debra Fraser, Administrator Corrective Action Plan: Management will ensure a review separate from the preparer of the reconciliation for the program?s reserve fund is completed with formal documentation noting the review. Anticipate Completion Date: 3/27/2023

View Audit 18909

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