Corrective Action Plans

Finding 553639 (2024-002)

Significant Deficiency 2024

CT

Procurement, Suspension & Debarment Reporting

Corrective Action Plan Finding No. 2024-002 – Suspension and Debarment U.S. Department of Education ALN: 93.493 Program Name: Congressional Deliverables Criteria: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify t...

Corrective Action Plan Finding No. 2024-002 – Suspension and Debarment U.S. Department of Education ALN: 93.493 Program Name: Congressional Deliverables Criteria: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.985 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University did not maintain formal documentation over its review of vendors for suspension and debarment. Cause: Due to turnover within the University the documentation of review was not maintained. Effect: Risk of noncompliance over the suspension and debarment compliance requirement. Questioned Costs: None Prevalence: There was no formal documentation over review for suspension and debarment Repeat Finding: This is not a repeat finding. Recommendation: We recommend that University update its policies to include formal documentation be maintained annually as evidence of its review of vendors not being suspended or debarred using the System for Award Management (SAM). Corrective Action Plan: 1. USJ will review and update its existing vendor policy to include the requirement that formal documentation be maintained annually as evidence of its review of vendors not being suspended or debarred using the System for Award Management. 2. The USJ Business Office will document a formal process consistent with the updated vendor policy to ensure efficient and effective compliance with the review of its vendor for not being suspended or debarred. Target Date of Implementation: 1. June 30, 2025 Responsible Party: Mr. James F. White, Vice President for Finance and Administration

View Audit 352217

Finding 553614 (2024-002)

Material Weakness 2024

Des Moines Area Metropolitan Planning Organization

IA

Reporting

The corrective action plan was documented in our response to the auditor’s comment. See the Schedule of Findings and Questioned Costs.

View Audit 352194

Finding 553613 (2024-001)

Material Weakness 2024

Des Moines Area Metropolitan Planning Organization

IA

Reporting Internal Control / Segregation of Duties

The corrective action plan was documented in our response to the auditor’s comment. See the Schedule of Findings and Questioned Costs.

View Audit 352194

Finding 553591 (2024-002)

Significant Deficiency 2024

Eastern Virginia Medical School

VA

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.1 § 200.403

Finding 2024-02: Indirect Costs (IDC) Views of Responsible Officials Management agrees with the finding and recommendations. Through the merger with Old Dominion University, additional controls have adopted around the processes and controls around the accuracy of the review over indirect costs calcu...

Finding 2024-02: Indirect Costs (IDC) Views of Responsible Officials Management agrees with the finding and recommendations. Through the merger with Old Dominion University, additional controls have adopted around the processes and controls around the accuracy of the review over indirect costs calculation requirements. Corrective Action Plan Effective July 1, 2024, EVMS merged with ODU and the ODU Research Foundation became the fiscal and administrative agent for EVMS’s transferring sponsored programs on behalf of ODU. As per ODU’s Memorandum of Understanding (MOU) with the ODU Research Foundation, the ODU Research Foundation has policies and processes in place to manage how the indirect costs are calculated. The ODU Research Foundation uses its own system of internal controls for IDC calculation with no reliance on ODU systems for those processes and are audited separately. As a corrective action moving forward, ODU management will notify the ODU Research Foundation management of the audit findings, so they are aware of the internal control deficiencies. ODU will request the Research Foundation to provide a copy of their single audit report to monitor continued compliance with Uniform Guidance. The corrective action plan will be completed by March 31, 2025 and the contact person for this finding is Victoria Dean.

View Audit 352191 Questioned Costs: $1

Finding 553590 (2024-002)

Significant Deficiency 2024

City of Dowagiac

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Equipment & Real Property Management

Finding 2024-002 Significant Deficiency and Noncompliance - Lack of Required Uniform Guidance Policies and Procedures Condition: The City did not update their federal policies and procedures to be in full compliance with Uniform Guidance. Anticipated Completion Date: September 30, 2025 Corrective Ac...

Finding 2024-002 Significant Deficiency and Noncompliance - Lack of Required Uniform Guidance Policies and Procedures Condition: The City did not update their federal policies and procedures to be in full compliance with Uniform Guidance. Anticipated Completion Date: September 30, 2025 Corrective Action: The City will implement a new policy document specifically for Uniform Grant Compliance to have one document to ensure compliance.

View Audit 352186

Finding 553486 (2024-004)

None 2024

University of Southern California

CA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.403

Management’s Views and Corrective Action Plan Management response to finding 2024-004: Review over cost transfers of subrecipient expenditures Cluster Name: Research and Development Federal Awarding Agency: Various Award Name: Various Award Number: Various Award Years: Various Assistance Listing T...

Management’s Views and Corrective Action Plan Management response to finding 2024-004: Review over cost transfers of subrecipient expenditures Cluster Name: Research and Development Federal Awarding Agency: Various Award Name: Various Award Number: Various Award Years: Various Assistance Listing Title: Various Assistance Listing Number: Various Pass-through entities: Various As described in Finding 2024-004, and as a result of improper training related to the implementation of the university’s new financial system in FY22, the university lacked adequate controls to identify the proper application of indirect costs as it relates to subrecipient expenses when using the cost transfer process to make corrections. Additionally, the university failed to properly apply its policy for the classification of subawards versus direct expenditures. As such, while cost transfers are a small percentage of overall transfer activity, an update to training materials will be made by June 2025 to educate cost transfer initiators on the proper method to use for this subset of subrecipient expenditures. Since February 2025, the Sponsor Projects Accounting (SPA) representative responsible for central office review of cost transfers now reviews to ensure that all intended grant related attributes are in effect before approving any subrecipient cost transfers. Additionally, as of February 2025, the university reinforced its policy regarding the classification of subawards versus direct expenditures with both the Procurement department and the SPA staff to ensure the proper expenditure classification is set up during the onboarding process of a contractor. The SPA team has completed its analysis and review of all previous subrecipient cost transfers to verify and correct the improper application of indirect cost limits and expenditure classifications. As of March 2025, all subrecipient cost transfer errors have been identified and corrected, resulting in questioned costs of approximately $587,000. Separately, this resulted in an under-recovery of $306,000 of indirect costs that were not charged to the original award. As all awards impacted are still open and active, the correcting expenditure adjustments were applied to the awards impacted that will affect future draw downs. Contact Person: Cindy Lee, Director, Sponsored Projects Accounting, cmlee@usc.edu

View Audit 352166

Finding 553483 (2024-001)

Material Weakness 2024

City of Scotts Valley

CA

Reporting Cash Management HUD Housing Programs

2024-001 Failure to comply with Reporong Requirements The grant was executed in October 2023, making the first reporong period to start January 2024. The City was unable to access the DRGR portal until late April 2024. During this period, the City maintained regular communica􀆟on with the HUD represe...

2024-001 Failure to comply with Reporong Requirements The grant was executed in October 2023, making the first reporong period to start January 2024. The City was unable to access the DRGR portal until late April 2024. During this period, the City maintained regular communica􀆟on with the HUD representa􀆟ve . A􀅌er gaining access the data was entered into the portal and the City has remained in communica􀆟ons with HUD representa􀆟ves. While the report was entered, there are addi􀆟onal steps to be able to submit. The City is ac􀆟vely working with DRGR staff to resolve a system issue that is not allowing us to complete the submi􀆫ng process. To date, the City has not received any no􀆟fica􀆟on from HUD indica􀆟ng that the performance reports are overdue, and they have been able to proceed with processing the reimbursement requests. The City has gained beter knowledge in rela􀆟on to the steps for full report submissions on the DRGR website and has strengthened internal controls on repor􀆟ng requirements, and grants management in general to avoid cases like this in the future Contact – Stephanie Hill, Administra􀆟ve Services Director Es􀆟mated Implementa􀆟on – June 30, 2025

View Audit 352165

Finding 553477 (2024-002)

Significant Deficiency 2024

Paine College

GA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Sup...

"Finding 2024-002 – U.S. Department of Education (USDE), Title IV Student Financial Aid Programs Planning (significant deficiency) Information on the federal program – Federal Direct Student Loans, FAL No. 84.268, June 30, 2024; Federal Pell Grants Program, FAL No. 84.063, June 30, 2024; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2024; Federal Work-Study Program, FAL No. 84.033, June 30, 2024 Criteria – Federal regulations governing Title IV programs. Condition – Non-compliances were noted, as more fully described in the context below. Questioned Costs – N/A Context – We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs 1) Three (3) out of 25 students had a credit balance on their account created by Title IV program funds longer than 14 days. 34 CFR 668.164(h)(1). Cause – Oversight by responsible employees. Effect – The College’s participation in the Title IV programs could be subject to USDE sanctions as applicable. Repeat Finding – No Auditor’s Recommendation – We strongly recommend the College refine the processes and procedures for the timely recording of disbursements in the general ledger allowing for more accuracy in financial reporting. View of Responsible Officials – The College has refined processes and procedures to ensure student refunds are processed within 14 days after the credit appears on the student account.

View Audit 352163

Finding 553476 (2024-001)

None 2024

Ritter Center

CA

Reporting

Views of Responsible Officials and Planned Corrective Actions The FFR report was submitted late due to the Director of Finance being new to the position and balancing vacancies in the Accounting Manager and Accounts Payable Clerk positions. There were many deadlines backlogged and the FFR report is ...

Views of Responsible Officials and Planned Corrective Actions The FFR report was submitted late due to the Director of Finance being new to the position and balancing vacancies in the Accounting Manager and Accounts Payable Clerk positions. There were many deadlines backlogged and the FFR report is one of those items. The Center has been experiencing stability in the key positions as well as expanding the department to include a Grants Administrator who will be responsible for grants reporting. Additionally, the Center is working on a Master Calendar of due dates to monitor and stay ahead of reporting deadlines. Person Responsible: Hector Zapeta Position of Responsible Party: Accounting Manager Anticipated Completion: June 30, 2025

View Audit 352161

Finding 553469 (2024-002)

Material Weakness 2024

The Howard University

DC

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: Accounts Payable (AP) will create a Corrective Action plan to include the following. 1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the u...

Name of Responsible Individual: Rawle Howard, Assistant Vice President, Procurement Corrective Action: Accounts Payable (AP) will create a Corrective Action plan to include the following. 1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. 2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding 3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel. Anticipated Completion Date: December 31, 2025

View Audit 352153 Questioned Costs: $1

Finding 552703 (2024-012)

Significant Deficiency 2024

The Howard University

DC

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.430

Name of Responsible Individual: Marchon Jackson, Associate Vice President for Research, Brenda Willis, Senior Executive Director of Financial Grants & Contracts, Jaquion Gholston, Assistant Vice President for Post-Award and UARC Operations Corrective Action: A new office is being developed to addres...

Name of Responsible Individual: Marchon Jackson, Associate Vice President for Research, Brenda Willis, Senior Executive Director of Financial Grants & Contracts, Jaquion Gholston, Assistant Vice President for Post-Award and UARC Operations Corrective Action: A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26. Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely. Anticipated Completion Date: July 1, 2025

View Audit 352153

Finding 551549 (2024-008)

Significant Deficiency 2024

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid

Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financi...

Name of Responsible Individual: Benjamin Carmichael, Associate Director for Compliance, Enrollment Management; Christina Veith, Associate Director of Loans, Financial Aid; Malik Artis, Interim Director of System, Office of Enrollment Systems; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: Howard University uses automated processes to identify and send loan disbursement notifications to parents and students. The nightly UC4 process prompted Banner to send out a Direct Loan notification to the student and/or parent. This UC4 process showed all students who had a Direct Loan disbursement after the last nightly UC4 process was run. During a compliance review of disbursement notifications during the Fall 2023 semester and the Loans Team worked with Banner consultants to determine the reason for this. While this issue was being reviewed and a solution created, the Loans Team used the RLRDLDD report in Banner, which is a report that showed all loans disbursed. This report could be matched against the UC4 listing of loans disbursed. This check between UC4 and the RLRDLDD report was used to send out loan notifications that was missed during the UC4 process during the Fall 2023 semester. During a Spring 2024 compliance review of disbursement notifications, it was discovered the RLRDLDD report was missing disbursements as well. As a corrective action, the Loans Team then began using a loan audit report out of the Argos reporting system to identify students who may have a disbursement not included in the UC4 and/or RLRDLDD report. The support time required for maintenance of Banner was also reduced due to the ongoing integration and implementation efforts to prepare Workday for the Fall 2024 semester. This increased the length of time it took to correct the UC4 process and RLRDLDD reports. Howard no longer uses Banner to send out Graduate PLUS, Subsidized and Unsubsidized loan notifications. Workday now is now responsible for sending out the disbursement notification after a loan has disbursed and there is a record in the student’s Activity History to document the loan notification has been sent. Parent PLUS Loan notifications must be sent out manually due to Workday not having the capability to send a disbursement notification to the parent’s email on file. The “FA CR Parent PLUS Disbursement Notification Report” is run weekly out of Workday to identify all Parent Plus Loan disbursements and a notification is sent to the parent’s email address on file. Bi-semester reviews are completed by the Associate Director for Compliance to ensure the loan disbursement notifications are being sent to students and parent in the required 30-day timeline. These reviews also ensure inclusion in the loan notification of all federally required information. Anticipated Completion Date: This corrective action plan was completed during Fall 2024 implementation of Workday. Monitoring and reviewing of loan disbursements has been ongoing to ensure the Workday system is correctly identifying and transmitting Direct Loan disbursements. Given that Workday is a new ERP, Howard recognizes maintenance and review of the disbursement notification process will be ongoing.

View Audit 352153

Finding 551543 (2024-003)

Significant Deficiency 2024

The Howard University

DC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Oliver Street, Interim University Registrar; Saleem Sullivan, Associate Registrar for Compliance; La Estes, Records Specialist; Ben Carmichael, Associate Director for Compliance, Enrollment Reporting; Sarah Mariner, Assistant Director for Compliance, Financial Aid Co...

Name of Responsible Individual: Oliver Street, Interim University Registrar; Saleem Sullivan, Associate Registrar for Compliance; La Estes, Records Specialist; Ben Carmichael, Associate Director for Compliance, Enrollment Reporting; Sarah Mariner, Assistant Director for Compliance, Financial Aid Corrective Action: The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP). Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future. Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date. Anticipated Completion Date: The correction to the length of each program in Workday was implemented during setup prior to the start of the Fall 2024 semester. There will be a Spring 2025 review performed by the Associate Director for Compliance to ensure the program length is accurately reported and testing shows this issue to be resolved. Each semester, enrollment reporting samples will be selected (approximately) 2 to 3 weeks after the first enrollment file for the semester is sent to NSC. Howard has set up a transmittal calendar with NSC which determines when enrollment files, including the graduate files, are transmitted. Due to work completed regarding the integration of Workday with NSC, Howard worked closely with NSC during Fall 2024 to troubleshoot issues that could delay enrollment files transmission. The schedule for submission of files was setup during this time. Howard currently has a vacancy at the University Registrar position and experienced individuals with Workday user knowledge will be pursued for hire. The hiring date for the University Registrar has not been approximated due to the positional requirement of Workday experience and the newness of the ERP system into the higher education space. The current Interim Registrar has prior University Registrar experience with knowledge of the requirements to be effective in the position.

View Audit 352153

Finding 551537 (2024-006)

Significant Deficiency 2024

The Howard University

DC

Student Financial Aid Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Sarah Mariner, Assistant Director for Compliance, Financial Aid; Robin Whitfield, Associate VP for Finance & Bursar; Guillermo Creamer, Collections Manager; Robert Muhammad, Executive Director o...

Name of Responsible Individual: Ben Carmichael, Associate Director for Compliance, Enrollment Management; Sarah Mariner, Assistant Director for Compliance, Financial Aid; Robin Whitfield, Associate VP for Finance & Bursar; Guillermo Creamer, Collections Manager; Robert Muhammad, Executive Director of Financial Aid; Brenda Willis, Senior Executive Director of Financial Grants & Contracts; Educational Computer Systems, Inc. Corrective Action: Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University. Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31. Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity. It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP. The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15. Anticipated Completion Date: Summer 2025 is the date the University anticipates having liquidated the Perkins program. Cash on Hand will be reported as of June 30 and updated again on October 31. Completion of the FISAP is due September 30, 2025 and final edits to the FISAP are due December 15, 2025. Howard will update the Cash on Hand and tuition and fees as of December 15, 2025 for final submission. The U.S. Department of Education will then review the submitted FISAP for errors or inconsistencies. Should there be no errors or inconsistencies from ED’s review, they will accept the FISAP and begin basing any Excess Liquid Capital return request on the Cash on Hand reported.

View Audit 352153

Finding 551531 (2024-001)

Significant Deficiency 2024

Alameda Health Consortium

CA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

The audit was filed late in 2023 due to an extended vacancy of a key finance position combined with the selection of a new audit firm, which resulted in additional time to prepare for and complete the audit. It is expected that this should not be an issue going forward.

View Audit 352145

Finding 551525 (2024-002)

Material Weakness 2024

Pontifical Catholic University of Puerto Rico

PR

Reporting

Management agrees with the noted finding. Re-mediating activities and control will be implemented in the next year.

View Audit 352134

Finding 551513 (2024-002)

None 2024

St. Thomas University Inc.

FL

Questioned Costs Student Financial Aid Reporting

The Business Office has implemented measure to ensure that all key items reported on the FISAP are accurate and if there have been changes or updates made after the initial FISAP reporting then a reconciliation will be performed so that the updates values will be reported prior to the deadline in De...

The Business Office has implemented measure to ensure that all key items reported on the FISAP are accurate and if there have been changes or updates made after the initial FISAP reporting then a reconciliation will be performed so that the updates values will be reported prior to the deadline in December. To ensure that all key items per the FISAP are properly reported the Business Office will: • Implement reconciliation and review processes to ensure compliance. • Following any update or reconciliation performed over FISAP reportable items the office will perform a check to ensure no key item amounts have changed. In the case that they do an updated FISAP will be reported. Contact Person: Kevin Doherty, Interim Controller Telephone: 305.628.6518 Email: kdoherty@stu.edu Anticipated Completion Date: 6/15/2025

View Audit 352117 Questioned Costs: $1

Finding 551510 (2024-002)

Significant Deficiency 2024

Homeless Assistance Leadership Organization, Inc.

WI

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.302

Action in response to finding: The Organization will either add internal resources to address the matters noted in the finding or outsource its accounting function to a third party with these capabilities. Name of the contact person responsible for corrective action: Yvonne MacDonald Hames Planned c...

Action in response to finding: The Organization will either add internal resources to address the matters noted in the finding or outsource its accounting function to a third party with these capabilities. Name of the contact person responsible for corrective action: Yvonne MacDonald Hames Planned completion date for corrective action plan: June 30, 2025

View Audit 352116

Finding 551509 (2024-002)

None 2024

Valor Christian College

OH

Special Tests & Provisions Reporting Internal Control / Segregation of Duties

FINDING 2024-002: UNTIMELY PAID CREDIT BALANCE- the auditor tested forty files, twenty-three of which had credit balances, and one credit balance was not paid in a timely manner. It is recommended the College increase controls over credit balances. Comments on Finding and Recommendation(s): We concu...

FINDING 2024-002: UNTIMELY PAID CREDIT BALANCE- the auditor tested forty files, twenty-three of which had credit balances, and one credit balance was not paid in a timely manner. It is recommended the College increase controls over credit balances. Comments on Finding and Recommendation(s): We concur with the finding and we believe that htis a unique situtaiton be we can create a revised review process. Actions Taken or Plannded: To address discrepancies in the student refund check process and prevent late returns the Finance Office will implement a structured verification and tracing procedure. After the Financial Aid office approves the calcuation sheets for refunds, a POPULI report capturing all credit balances from the start of the term to the latest financial aid disbursement will be generated. Finance Office will cross-reference refunds in process to determine completeness.

View Audit 352114

Finding 551505 (2024-002)

Material Weakness 2024

Clarkson University

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management accepts this finding and notes there were issues with the disbursement records that prevented them from being sent to COD. Unexpected turnover in the workforce resulted in 25% normal processing capacity during the timeframe in question. Staffing levels in that area have been fully restore...

Management accepts this finding and notes there were issues with the disbursement records that prevented them from being sent to COD. Unexpected turnover in the workforce resulted in 25% normal processing capacity during the timeframe in question. Staffing levels in that area have been fully restored with appropriate training to the employees. A formal schedule has been developed whereby records are reconciled and sent to COD on a weekly basis to reduce the risk of late filings. In addition, the University is considering methods of improved redundancy and backup to prevent systemic issues going forward. Anticipated Completion Date December 2024 - completed Responsible Person Nicole Adner, Director of Financial Aid

View Audit 352112

Finding 551503 (2024-005)

Significant Deficiency 2024

South Carolina State University

SC

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Student Financial Aid § 200.303

Corrective Action Plan The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken: 1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and ...

Corrective Action Plan The University acknowledges this finding and is committed to immediate corrective measures to ensure compliance with federal regulations. The following actions will be undertaken: 1. Enhance Procedures and Internal Controls: The University will strengthen its procedures and internal controls related to the submission of origination and disbursement records to the COD system. This includes implementing stricter monitoring mechanisms to ensure all records are submitted within the required timeframes. 2. Implement Advanced Technology Solutions: To improve the efficiency and accuracy of financial reporting, the University will adopt advanced technology solutions. These tools will facilitate timely and accurate submission of required data to the COD system. The newly established internal audit team will oversee the implementation and management of these corrective actions until the issue is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with federal origination and disbursement requirements. By taking these steps, the University aims to rectify the identified deficiency and prevent future occurrences, thereby maintaining the integrity of its financial reporting processes. Anticipated Completion Date: September 1, 2025

View Audit 352110

Finding 551493 (2024-001)

Significant Deficiency 2024

South Carolina State University

SC

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring § 200.303

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeki...

Corrective Action Plan The University acknowledges this finding and is committed to implementing immediate measures to ensure compliance with federal enrollment reporting requirements. The following steps will be undertaken: 1. Establish an Internal Audit Function: The University is actively seeking to fill a newly approved internal auditor position, with a dedicated budget line item to support this function. This role will provide leadership on all corrective action plans and serve as the primary contact for audit-related matters, ensuring onsite management for compliance issues within the University and its affiliated agencies. 2. Engage External Expertise: The Office of the Registrar will engage with the internal auditor and the National Student Loan Clearinghouse to review critical processes. This ongoing collaboration aims to assess the department’s strengths, weaknesses, opportunities, and threats, facilitating continuous improvement and compliance. 3. Enhance Staffing and Technological Resources: The University has made necessary staffing changes and will continue to evaluate the efficiency of the enrollment reporting process. This includes hiring additional staff as needed and incorporating advanced technology solutions to address this recurring issue. The implementation of enhanced technology will assist the Registrar in receiving alerts and status reports, ensuring timely and accurate processing. 4. Implement Robust Monitoring Systems: The University aims to generate necessary information and update systems to improve its capability to monitor student enrollment statuses, thereby enhancing compliance. This initiative will address challenges associated with certifying these enrollment status changes in a timely manner. 5. Strengthen Reporting Processes: Given the recurrence of this finding, the University will implement an enhanced reporting process, requiring the filing of transfer student status reports on a semester basis until the issue is resolved. The internal audit team will lead this reporting cycle, ensuring accountability and compliance. The internal audit unit will oversee and manage these corrective actions until the matter is fully resolved. The University is dedicated to enhancing its procedures and internal controls to ensure full compliance with enrollment reporting requirements. By implementing these measures, the University aims to rectify the identified deficiencies and prevent similar occurrences in the future, thereby upholding the integrity of its financial aid programs and maintaining compliance with federal regulations. Anticipated Completion Date: September 1, 2025

View Audit 352110

Finding 551444 (2024-006)

Significant Deficiency 2024

Volunteers of America Western Washington and Subsidiary

WA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.430

We acknowledge BDO’s recommendation to ensure consistent approval and retention of timesheets by both employees and supervisors for each pay period requested for reimbursement. However, VOAWW asserts that we have established controls in place to obtain and retain timesheet approvals, and the two ins...

We acknowledge BDO’s recommendation to ensure consistent approval and retention of timesheets by both employees and supervisors for each pay period requested for reimbursement. However, VOAWW asserts that we have established controls in place to obtain and retain timesheet approvals, and the two instances of missing approvals identified in the audit were due to human error rather than a lack of controls. To prevent such occurrences in the future and reinforce our existing procedures, we will continue implementing and strengthening the following controls: • Proactive Timesheet Approval Monitoring – Reports are regularly run to identify missing timesheet approvals before payroll is processed. Employees and supervisors with outstanding approvals receive reminders to ensure further action as needed, including notifying program directors about missing timesheet submissions or approvals resulting in out-of-compliance with federal awards and Uniform Guidance. • Real-Time Payroll Processing Checks – During payroll processing, additional reminders are sent to employees and supervisors who have not yet approved their timesheets, further reducing the likelihood of omissions. • Additional Approval Outside the System – In response to BDO’s recommendation, we will require managers to email Payroll at the end of every pay period affirming that they have reviewed and approved all timecards. This additional layer of approval ensures that even if a manager forgets to approve a timesheet in the system, there is still documented confirmation of their review. • Post-Payroll Compensating Control Implemented in FY24 – To mitigate any risk of over/undercharging grants due to miscoded time from unapproved timesheets, a compensating control was introduced in FY24. This process requires Program Management to review and approve a post-payroll report identifying any discrepancies in time allocations, ensuring that all time charged to grants is accurate and properly approved. • Documentation and Continuous Improvement – VOAWW provided attestations to BDO where available and acknowledges that the compensating control was not fully implemented during FY23 but was in place for most of FY24. Moving forward, we will ensure that this control is consistently applied across all programs. By maintaining and strengthening these controls, including the additional email approval process, we are confident in our ability to ensure proper timesheet approvals while mitigating any risk of inaccurate grant charging. Responsible Individual: Claire Danielson, Controller Estimated time of completion: June 2025

View Audit 352105

Finding 551393 (2024-005)

Material Weakness 2024

Hampton University

VA

Eligibility Reporting Matching / Level of Effort / Earmarking

Management agrees with this finding. The SSS director and staff will review the key line-item data at the point of entry to ensure the completeness and accuracy of information input into the Blumen system. Training will also be provided for the new administrative assistant. Prior to submitting the A...

Management agrees with this finding. The SSS director and staff will review the key line-item data at the point of entry to ensure the completeness and accuracy of information input into the Blumen system. Training will also be provided for the new administrative assistant. Prior to submitting the APR, a download of all data categories will be reviewed for accuracy and completeness.

View Audit 352091

Finding 551391 (2024-004)

Material Weakness 2024

Hampton University

VA

Student Financial Aid Special Tests & Provisions Reporting

The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors within Banner, so we do not have these concerns in the future. The Architect students mapping issue was corrected by the Registrar Office in March 2025. The Registrar’s ...

The University concurs with the finding. The University is working with the Clearinghouse and consultants to correct system errors within Banner, so we do not have these concerns in the future. The Architect students mapping issue was corrected by the Registrar Office in March 2025. The Registrar’s Office has created a new program code that will reflect next semester’s registrations and updated previous majors.

View Audit 352091

Corrective Action Plans

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