Corrective Action Plans

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2024-007 Research and Development Cluster – Federal Assistance Listing Nos. 84.017 and 47.081 – Period of Performance Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related ...
2024-007 Research and Development Cluster – Federal Assistance Listing Nos. 84.017 and 47.081 – Period of Performance Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related to the grant reconciliation and recording process to ensure expenses are reflected prior to the grant ending and recorded in the correct period on the SEFA. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: Restricted Funds Accounting (RFA) team has restructured with new leadership and added all new staff. RFA will train new staff, develop and update policies and procedures, and automate processes within ERP systems, as appropriate. RFA is creating current and updated SOPS for each task and making sure the current staff is learning processes the correct way; this includes reconciliation and recording in the correct period. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting, Tonya Cardwell. Planned completion date for corrective action plan: December 2026
2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally...
2024-003 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.063, and 84.268 – Enrollment Reporting Recommendation: We recommend the University evaluate its procedures and review policies in overseeing submissions to the NSLDS completed by the third-party servicer. Additionally, we recommend the University review its policies and procedures on reporting enrollment information to the NSLDS to ensure that all relevant information is being captured and reported timely in accordance with applicable regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar’s Office will review and strengthen the enrollment report to ensure it pulls all required information according to the needs of the National Student Clearinghouse (NSCL) and the National Student Loan Data System (NSLDS). The Registrar’s Office will continue to work with the National Student Clearinghouse (NSCL) and National Student Loan Data System (NSLDS) on the specific enrollment submission scenarios that require a different submission/update requirement. Name(s) of the contact person(s) responsible for corrective action: University Registrar, Dr. Genita Mangum Planned completion date for corrective action plan: December 2025
Action taken in response to finding: A formal review of will take place of NSLDS reporting. Written policy with a monthly checklist will be developed to be in compliance with the regulation for student statuses. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Plan...
Action taken in response to finding: A formal review of will take place of NSLDS reporting. Written policy with a monthly checklist will be developed to be in compliance with the regulation for student statuses. Name(s) of the contact person(s) responsible for corrective action: Patrick Farley Planned completion date for corrective action plan: June 30, 2025
Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to impro...
Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to improve segregation of duties where possible and follow the Committee of Sponsoring Organizations of the Treadway Commission best practices for small business. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025.
All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be e...
All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.
Finding #2024-002 - Lack of Financial lose Process and Delayed Accounting Condition: Cash and other accounts were adjusted during the audit process. Many audit journal entries were required to record and adjust activity. Effect: Financial reporting from the District's general ledger could be materi...
Finding #2024-002 - Lack of Financial lose Process and Delayed Accounting Condition: Cash and other accounts were adjusted during the audit process. Many audit journal entries were required to record and adjust activity. Effect: Financial reporting from the District's general ledger could be materially misstated. Delayed grant claims could cause cash flow issues. Cause: The District did not have procedures in place to ensure that all transactions were properly recorded on the general ledger prior to the audit. Criteria: During the close of the monthly financial statements, other balances should be reconciled to subsidiary detailed listings. Grant claims should be reconciled to the general ledger and submitted throughout the year. Receivables should be recorded as of year end as needed. Recommendation: The District should develop procedures to timely reconcile cash and other balance sheet accounts. The reconciliations should be reviewed by someone other than the person preparing the reconciliations. The reviewer should initial and date the reconciliations when the review is complete. The District should reconcile payroll liabilities. The District should develop procedures to review and submit grant claims throughout the year and reconcile to the general ledger. Response: The District will work to establish procedures to reconcile accounts monthly and grant claims are reconciled and submitted throughout the year. Contact Person: Jessie Backes, Interim Business Manager Anticipated Completion Date: Ongoing
Finding 544132 (2024-001)
Significant Deficiency 2024
Name of Contact Person: Trang Nguyen Corrective Action: The Community Development Department has implemented the following steps for FY 2025. 1. Updated the City’s policy to iden􀆟fy the Housing Manager or designee as the responsible repor􀆟ng party to submit the reports by the submission deadline. 2....
Name of Contact Person: Trang Nguyen Corrective Action: The Community Development Department has implemented the following steps for FY 2025. 1. Updated the City’s policy to iden􀆟fy the Housing Manager or designee as the responsible repor􀆟ng party to submit the reports by the submission deadline. 2. Added to the policy administra􀆟ve support staff to set calendar reminders in outlook for follow up. 3. Finance will add to the quarterly and year-end checklist to ensure 􀆟mely repor􀆟ng. Proposed Completion Date: June 30, 2025
Finding 544096 (2024-002)
Significant Deficiency 2024
Finding No. 2024-002: Compliance Reporting Description of Finding: The Organization submitted periodic reports that did not reconcile to the accounting records and were not submitted by the due date. Statement of Concurrence or Nonconcurrence: The organization agrees with this finding. Corrective Ac...
Finding No. 2024-002: Compliance Reporting Description of Finding: The Organization submitted periodic reports that did not reconcile to the accounting records and were not submitted by the due date. Statement of Concurrence or Nonconcurrence: The organization agrees with this finding. Corrective Action: In August 2024 the Organization engaged the services of an outside consultant who is a practicing CPA with extensive experience auditing not-for profit organizations. Policies and related procedures have been implemented to ensure the books and records are closed on a monthly basis and all reports are reviewed for agreement with the accounting records and approved prior to being filed. Name of Contact Person: Kellyann Day Chief Executive Officer, (203) 492-4866, kday@newreach.org Projected Completion Date: The project is anticipated to be completed during fiscal year 2025.
With respect to the American Rescue Plan (ARP)- ESSER Program: o The District's budget report related to the American Rescue Plan - ESSER program be reviewed to ensure that appropriations and resulting balances accurately reflect remaining program funds available. o The...
With respect to the American Rescue Plan (ARP)- ESSER Program: o The District's budget report related to the American Rescue Plan - ESSER program be reviewed to ensure that appropriations and resulting balances accurately reflect remaining program funds available. o The Board resolution approving hourly rates for employees funded by the American Rescue Plan - ESSER program be amended to reflect revised contractual rates. In addition, timesheets for such employees be signed for approval by the appropriate supervisory personnel.
The District's budget report related to the ESEA Title IV program be reviewed to ensure that appropriations and resulting balances accurately reflect remaining program funds available.
The District's budget report related to the ESEA Title IV program be reviewed to ensure that appropriations and resulting balances accurately reflect remaining program funds available.
Finding Number: 2024‐002 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Education Facilities, Operation, and Maintenance Assistance Listing Numbers: 15.042, 15.047 Contact Person: Aurelia Tapaha, Business Manager Anticipated Completion Date: April 2025 Planned Corrective...
Finding Number: 2024‐002 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Education Facilities, Operation, and Maintenance Assistance Listing Numbers: 15.042, 15.047 Contact Person: Aurelia Tapaha, Business Manager Anticipated Completion Date: April 2025 Planned Corrective Action: The School will start submitting SF‐425 Quarterly report before the last day of the month. Attend training provided by Bureau of Indian Education to learn of compliance with federal regulations and guidelines.
Finding 544082 (2024-001)
Significant Deficiency 2024
2024-001 Enrollment Reporting (Significant Deficiency), Department of Education, Student Financial Aid Cluster, Special Tests and Provisions Condition: The College did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Unless it ...
2024-001 Enrollment Reporting (Significant Deficiency), Department of Education, Student Financial Aid Cluster, Special Tests and Provisions Condition: The College did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended (34 CFR 685.309(b)(2)(i)). Cause: The College does not have adequate procedures in place to ensure students’ enrollment statuses are updated on NSLDS timely. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the students’ loans. The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: From a population of 42 students that withdrew officially during a term, we tested 5 students and noted that all 5 were not reported timely. Recommendation: We recommend that the College put procedures in place to ensure that any changes in student enrollments are properly tracked and updated to the NSLDS. Management Response: When the Registrar’s Office is notified of a student’s withdrawal (official or unofficial), within 24 hours the student’s record in the National Student Clearinghouse will be manually flagged as withdrawn with their last date of attendance. Party responsible: Sherry A. Phelps Office phone: 540-828-5313 Email address: sphelps2@bridgewater.edu Expected date of correction: This problem was corrected on 6/27/2024 when it was brought to my attention and since that date the required information has been correctly reported directly into the National Student Clearinghouse within 24 hours of the date of determination of a student’s withdraw from the college.
Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 7,2025 Planned Corrective Action: WUSD2 has designed and implemented an effective internal ...
Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 7,2025 Planned Corrective Action: WUSD2 has designed and implemented an effective internal control procedure to ensure that the federal reporting is tracked and completed in a timely manner. The Business Manager and Federal Programs Director will meet monthly to review grant funding and reporting. This will include any deadlines for submissions of grants and reporting.
Contact Person: Business Manager Planned Corrective Action: The Business Manager currently maintains a file which includes documentation in support of all amounts submitted on federal quarterly SF-425 reports. Planned Completion Date: Throughout the fiscal year ending June 30, 2025 and ongoin...
Contact Person: Business Manager Planned Corrective Action: The Business Manager currently maintains a file which includes documentation in support of all amounts submitted on federal quarterly SF-425 reports. Planned Completion Date: Throughout the fiscal year ending June 30, 2025 and ongoing
Management acknowledges the recommendation and has begun considering controls consistent with the recommendation. Appropriate year-end closing procedures will be written to document required reconciliations and related internal controls over completeness and accuracy.
Management acknowledges the recommendation and has begun considering controls consistent with the recommendation. Appropriate year-end closing procedures will be written to document required reconciliations and related internal controls over completeness and accuracy.
Finding 544054 (2024-001)
Significant Deficiency 2024
SIGNIFICANT DEFICIENCY 2024-01 Financial Reporting Recommendation: The organization should ensure: • Internal controls are in place and performed throughout the year to enable an efficient year end closing process. • Documentation of the performance of internal reviews over reconciliations and jour...
SIGNIFICANT DEFICIENCY 2024-01 Financial Reporting Recommendation: The organization should ensure: • Internal controls are in place and performed throughout the year to enable an efficient year end closing process. • Documentation of the performance of internal reviews over reconciliations and journal entries is retained and is readily available. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An external application is now being used to track reviews of journal entries and reconciliations to make up for this being a missing feature in the accounting system. Name(s) of the contact person(s) responsible for corrective action: Noah Masson Planned completion date for corrective action plan: 8/1/2024
Finding Number: 2024-002, Effort Certification Condition: One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating ...
Finding Number: 2024-002, Effort Certification Condition: One of the internal controls that the University has designed related to ensuring that personnel expenses charged to federal grants were accurate is an effort certification that is completed at least annually. This control was not operating effectively during the year ended June 30, 2024, as certain effort certifications were not completed timely. Planned Corrective Action: Penn State raised awareness of the late effort certification issue at various committee and council meetings during Fall 2024 and enforced compliance with our existing policy. These meetings involve research leadership at all colleges, such as Associate Deans for Research, College Research Administration Officers, and College Financial Officers. Penn State followed its policy on overdue effort certifications, and we have implemented additional internal controls in the process. The University’s Office of the Senior Vice President for Research has restructured oversight of effort certification, along with many other post award financial matters, to a newly created office, Post Award Contractual Compliance (PACC). This office includes the existing Research Accounting Office (which was part of the Office of Budget and Finance prior to July 1, 2024), and Penn State has hired an Assistant Vice President to oversee this team. A new suboffice, led by a new director, within PACC is the Financial Analysis and Compliance Office (FACO), which is responsible for central oversight and training over the effort certification process. This office has recently created a new dashboard to monitor the completion of effort certifications and works closely with business units within Penn State to ensure timely completion via sending out reminders, holding meetings, and providing training on the process. Contact person responsible for corrective action: John Hanold, Associate Vice President for Research; Director, Office of Research Administrative Services Anticipated Completion Date: June 30, 2025
Federal Program: U.S. Department of Education Federal Direct Loan Program, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR Section 685.309(b). Condition: During our testing of 40 students for eligibility, we noted three students in which the students' ...
Federal Program: U.S. Department of Education Federal Direct Loan Program, Federal Assistance Listing 84.268 Criteria: The University is required to comply with 36 CFR Section 685.309(b). Condition: During our testing of 40 students for eligibility, we noted three students in which the students' status change was not timely reported to the National Student Loan Database System (NSLDS). Corrective Actions Taken or Planned: For the year ended June 30, 2024, three students were reported late to NSLDS. Each student, after being identified, were then reported to NSLDS with the correct status and date. The Office of Institutional Research will work with the Registrar’s Office to ensure that students are reported in a timely manner. The Director of Institutional Research has provided the following steps that will be taken when a student is reported as withdrawn: 1. View the student's transcript in Ellucian to see if he/she withdrew or is back-dated as never enrolling. 2. Update Excel file for the term enrollment accordingly. 3. Update National Student Clearinghouse (NSC) file that will be submitted on the next due date. 4. Manually update the student's enrollment in National Student Clearinghouse 5. Manually update the student's enrollment in NSLDS Name of Responsible Person: Daniel Donner, Director of Financial Aid Completion Date: August 13, 2024
2024-002 C. Cash Management; L. Reporting Evidence and Review and Approval of the Reported Expenditures and Timely Report Submission Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommen...
2024-002 C. Cash Management; L. Reporting Evidence and Review and Approval of the Reported Expenditures and Timely Report Submission Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: Management should reassess the design of its controls to ensure submissions to BHSB are made timely within the required 15-day period and that documentation is retained that evidences the review and approval of expenditures submitted to BHSB for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendations. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue educating grant managers on capabilities within the system that can be utilized in the execution of review and approval of grant expenditures prior to timely submission to the relevant granting agencies for reimbursement. Centralized repositories have been set up for grant managers to extract specific monthly financial reports for use in the execution of their controls, as well as to retain their review and approval evidence. Additionally, management will develop a federal grant policy that includes the requirements for compliance and internal controls for federal grants. The policy will acknowledge that for controls to be designed and operate effectively, there must always be a segregation of duties between the preparer of the control vs. reviewer and that clear documentation must be retained to evidence the execution of the controls. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu
2024-001: Financial Reporting Management agrees with the finding and has taken immediate steps to address the issue and ensure timely submissions. Grand Street Settlement and BTQ Financial, Inc. will jointly oversee and ensure the timely submission of all progress reports. All agreements will be re...
2024-001: Financial Reporting Management agrees with the finding and has taken immediate steps to address the issue and ensure timely submissions. Grand Street Settlement and BTQ Financial, Inc. will jointly oversee and ensure the timely submission of all progress reports. All agreements will be reviewed in detail to fully understand compliance and reporting requirements, ensuring that all conditions are met, and submissions are made on time. A detailed timeline will be established for each reporting period, with regular check-ins to ensure that progress reports are completed and submitted on schedule. All deadlines will be closely monitored to prevent any future delays. Status of Finding: Management is expected to resolve the finding during fiscal year 2025 and will continue to work on resolving the finding. Managements Response: Management agrees with the finding. The issue will be corrected and resolved by the Grand Street Settlement Director of Administration, Program Director, and BTQ Financial during the fiscal year 2025.
Finding No. 2024-004: Segregation of Duties and Oversight – Material Weakness in Internal Control over Financial Reporting Contact for Corrective Action: Matt Bergheiser, President The finance department will institute a monthly financial reporting package to be sent to the President of the organi...
Finding No. 2024-004: Segregation of Duties and Oversight – Material Weakness in Internal Control over Financial Reporting Contact for Corrective Action: Matt Bergheiser, President The finance department will institute a monthly financial reporting package to be sent to the President of the organization which will include the monthly financial statements, general ledger detail, a listing of all journal entries made, significant accounts reconciliations, aged payables and receivables, and any significant adjustments in the previous period. Report will also include an update to the Schedule of Federal Awards and other significant grant reporting done in conjunction with the development team. President will review and approve the packet monthly. Expected Completion Date: 3/31/2025
Finding 541990 (2024-004)
Significant Deficiency 2024
Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Corrective Action Plan: Previously, this was an ancillary work task for a staff member in a different department. CU has since hired an experienced Registrar and ...
Federal agency: U.S. Department of Education Programs: Federal Direct Student Loans Assistance listing #: 84.268 Award year: 2024 Corrective Action Plan: Previously, this was an ancillary work task for a staff member in a different department. CU has since hired an experienced Registrar and begun training an Associate Registrar. The dedicated department now updates Clearinghouse on the required monthly basis. All previous records have been corrected. Timeline for Implementation of Corrective Action Plan: Completed Contact Person: Mark Hartonchik, CFO
Corrective Action Plan: Please describe below how the situation in the finding will be corrected. What action(s) will be done (refer to finding recommendation and agency response) The SAWDB will strengthen the process in which it monitors compliance with the requirements of Section 129(a)(4)(A), W...
Corrective Action Plan: Please describe below how the situation in the finding will be corrected. What action(s) will be done (refer to finding recommendation and agency response) The SAWDB will strengthen the process in which it monitors compliance with the requirements of Section 129(a)(4)(A), WIOA, 128 Stat. 1506 and develop a strategy to exceed the minimum 75 percent of funds to out-of-school youth. Quarterly review and monitoring will take place during the Monitoring Committees meeting. The fiscal administrator will provide the report. A direct review of percentages of expenditures will be analyzed by fiscal administrator, Program Manager, Program Monitor, and WIOA Administrator prior to reporting to the monitoring committee. Who will act (name and title): Skylar Arnold, Fiscal Admin Glory Juarez, WIOA Admin Jaymi Simms WIOA Program Manager When will action(s) be completed (effective dates, timelines, etc.): SAWDB will ensure that Earmarking Compliance is reviewed and maintained at or over the minimum percentage allowed. This is start immediately and reported to Monitoring Committee Quarterly. These enhanced procedures will be performed to resolve this finding before June 30, 2025.
State and Local Fiscal Recovery Funds– Assistance Listing No. 21.027 Allowable Activities and Costs - Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Commission establish policies and procedures over internal controls to ensure review and approval of SEFA...
State and Local Fiscal Recovery Funds– Assistance Listing No. 21.027 Allowable Activities and Costs - Significant Deficiency in Internal Control Over Compliance Recommendation: We recommend the Commission establish policies and procedures over internal controls to ensure review and approval of SEFA preparation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Commission will implement a SEFA preparation policy. Name of the contact person responsible for corrective action: Tracie Thomas Planned completion date for corrective action plan: May 31, 2025
The Controller will review the detailed information related ot the drawdown to ensure the amount charged to the specific grant is allowable, reasonable and properly supported prior to when the drawdown is requested.
The Controller will review the detailed information related ot the drawdown to ensure the amount charged to the specific grant is allowable, reasonable and properly supported prior to when the drawdown is requested.
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