Corrective Action Plans

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Finding 539593 (2024-001)
Significant Deficiency 2024
Occidental College Corrective Action Plan Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Explanation of Deficiency: Occidental sent a degree file to the National Student Clearinghouse (NSC) on June 12, 2024. It was...
Occidental College Corrective Action Plan Finding 2024-001 – Special Tests and Provisions – Enrollment Reporting: Significant Deficiency in Internal Control Over Compliance Explanation of Deficiency: Occidental sent a degree file to the National Student Clearinghouse (NSC) on June 12, 2024. It was a sent a week after an enrollment file. The enrollment file had errors which required resolution before the NSC could process the degree file. The enrollment file errors were remedied on June 25, 2024. The degree file also had errors posted on June 26, 2024, and corrected by Occidental on July 29, 2024. Correction Action Plan: The staff member currently responsible for resolving National Student Clearinghouse (NSC) file errors has now been trained in the institutional responsibility to send NSC files on time and to resolve any resulting errors immediately. In additional, the College will soon be hiring an administrative position (currently open) in the Registrar’s Office who will act as Occidental’s main liaison with the NSC. Plans for the new liaison training include both NSC processing as well as the relationship between NSC submissions and the institutional responsibility to report accurate enrollment to the National Student Loan Data System (NSLDS) as required. Training will be conducted by the Registrar with the assistance of the Director of Financial Aid for emphasis on institutional responsibilities as outlined in 34 CFR 685.3096(b). Contact Person Responsible for Corrective Action: James Herr, Occidental College Registrar Anticipated Completion Date: December 12, 2024 (end of Fall semester but before next degree file is sent to NSC)
Contact Person Mary Vandal, Business Manager Planned Corrective Action This finding was noted by the auditors on the Impact Aid application submitted in January 2023. Both applications submitted in January of 2024 and 2025 had the proper support showing student enrollment information with review or ...
Contact Person Mary Vandal, Business Manager Planned Corrective Action This finding was noted by the auditors on the Impact Aid application submitted in January 2023. Both applications submitted in January of 2024 and 2025 had the proper support showing student enrollment information with review or approval by tribal authority prior to submitting the application. Applications made in the future will continue to have the required documentation to support the application. Planned Completion Date June 30, 2025
DCHS has reviewed its procedures and will ensure that suspension and debarement status is documented prior to contracting with a vendor.
DCHS has reviewed its procedures and will ensure that suspension and debarement status is documented prior to contracting with a vendor.
COD Reporting Errors Audit Finding: Two students had incorrect disbursement information reported. Out of a population of 6,385 students with disbursements during the Spring and Fall semesters of the 2024 aid year, 25 were selected for testing. Of those students, two had the incorrect disbursement d...
COD Reporting Errors Audit Finding: Two students had incorrect disbursement information reported. Out of a population of 6,385 students with disbursements during the Spring and Fall semesters of the 2024 aid year, 25 were selected for testing. Of those students, two had the incorrect disbursement date reported. Our sample was not, and was not intended to be, statistically valid. Cause of the Finding: The University did not have appropriate controls in place to ensure accurate reporting. Effect of the Finding: The University reported inaccurate information and, as such, ED was not provided accurate information. Acknowledgement of the Finding: We acknowledge the audit finding regarding the discrepancies between the disbursement dates reported to the Common Origination and Disbursement (COD) system and the actual disbursement dates. We understand the importance of aligning these dates to ensure accurate federal reporting and compliance with Title IV regulations. Risk Acceptance: After careful consideration, we have determined that we are willing to accept the risk associated with the mismatches in COD disbursement dates. We believe that the discrepancies identified have not resulted in significant adverse impacts on our federal aid programs or student aid disbursement processing. Furthermore, we assess that the likelihood of material financial or operational consequences arising from these discrepancies is low. Rationale for Accepting the Risk: o The mismatched disbursement dates were not caused by fraudulent activity or intentional misreporting. o There is no evidence of overpayments or underpayments of Pell Grant funds to students as a result of the discrepancies. o The institution has a long history of successfully managing federal aid programs, and the current system's checks and balances are deemed adequate to ensure that aid is disbursed correctly, even if the dates reported to COD do not exactly match the dates the funds were disbursed. o The impact on reconciliation and compliance has been minimal, and we have not encountered significant issues in our annual reviews with the Department of Education. o The mismatches are not expected to have any significant impact on our ability to meet Title IV reconciliation deadlines or other reporting requirements. Mitigating Actions: While we are willing to accept the risk associated with these mismatches, we will continue to take steps to mitigate any potential negative impacts and improve our internal processes, including: o Monitoring and Review: We will conduct periodic reviews to identify any significant discrepancies and address them promptly. Any material issues that arise in the future will be corrected as needed. o Reconciliation Process: We will continue to ensure that our reconciliation process between our internal system and COD is robust, even if mismatched dates are accepted. Any discrepancies will be reviewed at regular intervals to verify accuracy. o Training: We will provide ongoing training to staff responsible for Pell Grant disbursements and reporting to COD to ensure they are aware of the risks and potential consequences of incorrect disbursement date reporting. o Documentation of Decisions: We will maintain documentation of the decision to accept the risk and will revisit this decision as part of our annual risk assessment to ensure that it continues to align with institutional goals and compliance objectives. Conclusion: We are confident that the risk of COD disbursement date mismatches will not significantly impact our overall compliance or federal aid management. However, we remain committed to continuous monitoring and improvements in our processes to ensure accurate reporting and minimize any potential future issues. Responsible Parties: The Vice President for Enrollment and Student Success, Associate Vice President of Enrollment Management, and the Senior Director Student Financial Services and Operations. Responsible party contact information is located at uco.edu.
NSLDS Reporting Errors Audit Finding: Eight students had incorrect enrollment information reported, two students had enrollment status changes that were not reported timely, and one student had an address change that was not reported timely. Out of a population of 4,479 students with status changes...
NSLDS Reporting Errors Audit Finding: Eight students had incorrect enrollment information reported, two students had enrollment status changes that were not reported timely, and one student had an address change that was not reported timely. Out of a population of 4,479 students with status changes during the Spring and Fall semesters of the 2024 aid year, 40 were selected for testing. Of those students, four had the incorrect program begin date reported, one had the incorrect program enrollment effective date reported, one had the incorrect program length reported, two had the incorrect CIP code reported, two students had enrollment status changes that were not reported timely, and one student had an address change that was not reported timely. Our sample was not, and was not intended to be, statistically valid. Cause of the Finding: The University did not have appropriate controls in place to ensure timely and accurate reporting. Effect of the Finding: The University reported inaccurate information or failed to report changes within the required time frame and, as such, ED was not provided accurate and timely information. Corrective Action Plan: To address the errors identified in the NSLDS reporting, the following corrective actions will be taken: 1. Immediate Review and Correction of Existing Data o Conduct a review of federal student aid records for the past nine months to identify and correct any discrepancies in loan amounts, disbursement dates, and borrower statuses reported to NSLDS. o Work with the SIS vendor and ED to ensure that all data submissions to NSLDS are accurate and complete. 2. System Integration and Process Improvement o Implement a data validation process that cross-checks loan disbursements and borrower statuses against internal records before submitting to NSLDS. o Enhance the SIS to NSLDS data mapping interface to ensure consistency and accuracy of loan-related information between the two systems. 3. Training for Staff o Provide targeted training for financial aid office staff responsible for NSLDS reporting, emphasizing proper data entry practices, system integration, and error-checking protocols. o Review periodic refresher courses to ensure staff remains up to date on any changes to NSLDS reporting requirements. 4. Ongoing Monitoring and Reconciliation o Establish a routine process to reconcile NSLDS data with internal student aid records monthly, ensuring discrepancies are caught and corrected promptly. o Implement a monthly review of the NSLDS submission to confirm all data is up to date, including loan disbursements, borrower status updates, and any adjustments. 5. Timeline for Implementation o Review and correction of existing NSLDS errors, as needed: Completed by June 30, 2025. o System and integration review: Completed by June 30, 2025. o Staff training sessions: First session scheduled by June 30, 2025, with periodic refreshers as available. o Ongoing monitoring process implementation: Ongoing starting immediately. 6. Responsible Parties The Vice President for Enrollment and Student Success, Associate Vice President of Enrollment Management, and the Registrar will oversee the implementation of the corrective action plan. Responsible party contact information is located at uco.edu.
Finding Number: 2024-002 Condition: Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. Planned Corrective Action: ECDI has created a calendar for deadlines that has been shared between Development, Fiscal, and Program managers to ensure all deadlines are m...
Finding Number: 2024-002 Condition: Organization failed to submit the SF PPR report as of December 31, 2023 by January 30, 2024. Planned Corrective Action: ECDI has created a calendar for deadlines that has been shared between Development, Fiscal, and Program managers to ensure all deadlines are met. Multiple notifications are provided to these parties in advance of due dates. Contact Person Responsible for Corrective Action: Brian Barrett, Hudu Ahmed and Louisa Dallett Completion Date: March 1, 2025
Finding Number: 2024-001 Condition: GBQ identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of ho...
Finding Number: 2024-001 Condition: GBQ identified errors in how employee time was allocated to the program, and salaries and wages allocated to the program in excess of the Executive Level II Salary maximum. Specifically, one employee had salaries and wages allocated to the program in excess of hours tracked to the program for a selected month. Another employee had an inappropriate wage rate applied to allocated time to the program. Last, two employees had compensation levels allocated to the program in excess of the Executive Level II Salary max amount in effect for the respective period. Planned Corrective Action: ECDI will put additional steps in place in Payroll Review process to ensure reconciliation of payroll charges to actual time records and rates. The organization will modify it's calculations to ensure that pay rates are reflective of the timeframe in question (not for periods before or after). ECDI will update its calculations to include thresholds for Executive pay so they are not entered in excess of approved rates. The company is also exploring technology enhancements so that information from ECDl's Payroll system flows directly into ECDl's Accounting system to limit the chance of errors during extraction from Payroll system and uploading into Accounting system. Contact Person Responsible for Corrective Action: Brian Barrett and Hudu Ahmed. Completion Date: In process
View Audit 350075 Questioned Costs: $1
Corrective Action Plan for Finding 2024-004 Community Care agrees with this finding. There are four bullets in this finding. We will be making a formal request to have the HMIS 72 hour data entry removed from our contract. The HMIS system does not have the capability to measure data entry timefram...
Corrective Action Plan for Finding 2024-004 Community Care agrees with this finding. There are four bullets in this finding. We will be making a formal request to have the HMIS 72 hour data entry removed from our contract. The HMIS system does not have the capability to measure data entry timeframes because of this we would need to design a data entry tracking process to track the timeframes. If our request is denied, we will create an entry tracking process. Bullets 2-4 are results of providing services in from the perspective of a low barrier service. Our priority is to have youth come to a safe place that is warm and where they are provided with a place to sleep, food, healthcare, and services to aid them. Staying in the program is not contingent on completing assessments or engaging in a service planning process. Each time a youth is in a program they are provided with the opportunity to participate in an assessment and are offered an organized service plan. Most participate but some do not. We will continue to offer the same level of support and opportunity for assessments and service planning to each youth. • There was no auditable evidence to test whether the participants were entered into HMIS within 72 hours. • Four participants did not have a service plan developed within 30 days. • The client was unable to provide the NavSEA for three participants. • The service plan for one participant did not have documented review. Responsible Official: David McCluskey, Executive Director Date of Corrective Action: Systems are in place and efforts will continue to encourage youth to participate in assessments and service planning practices. Regarding the HMIS data entry request will be made Friday the 21st March, 2025. If denied we will build a tracking process within 30 days.
2024-002 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: Region III will establish cle...
2024-002 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: Region III will establish clear documentation checklist with requirements for each report to ensure completeness and accuracy. Assign specific roles and responsibilities for report preparation, review and approval before submission to ensure that multiple levels of review are in place.
View Audit 350052 Questioned Costs: $1
Finding 2024-003 – Capital Fund Grant Reconciliations – Special Tests – Significant Deficiency Capital Fund Program – ALN #14.872 Corrective Action Plan: The Housing Authority has brough forward all schedules related to Capital Fund Grant as of March 2025. Person Responsible: Sheila Crisp, Executi...
Finding 2024-003 – Capital Fund Grant Reconciliations – Special Tests – Significant Deficiency Capital Fund Program – ALN #14.872 Corrective Action Plan: The Housing Authority has brough forward all schedules related to Capital Fund Grant as of March 2025. Person Responsible: Sheila Crisp, Executive Director Anticipated Completion Date: June 2025
Finding 539480 (2024-010)
Significant Deficiency 2024
Cash Management – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit...
Cash Management – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Director will ensure that when processes are completed, they are verifiable through documentation. Credit Balance refunds as well as drawdowns will be tracked for proper compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025
Finding 539478 (2024-009)
Significant Deficiency 2024
Special Tests and Provisions Direct Loan Reconciliation – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding:...
Special Tests and Provisions Direct Loan Reconciliation – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid director will institute a documented review of the Direct Loan reconciliations prepared by Campus Ivy or future third-party processors. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025
Finding 539474 (2024-007)
Significant Deficiency 2024
Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...
Eligibility – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid office will be implementing an SOP which will document a review process of work done by the third-party processor, to include COD reporting, and Verification procedures. We will also be implementing a process to review students who need to complete their exit counseling. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025
View Audit 350009 Questioned Costs: $1
Finding 539472 (2024-006)
Significant Deficiency 2024
Special Tests and Provisions Gramm-Leach-Bliley Act– Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: Ther...
Special Tests and Provisions Gramm-Leach-Bliley Act– Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The IT department continues to improve its processes; an annual review of the WISP has been started and will continue. The Financial Aid Office will work with IT to make sure that the WISP is improved to include and provide secure disposal of customer information and make sure the review is documented. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Student Financial Aid Director Planned completion date for corrective action plan: 6/30/2025
View Audit 350009 Questioned Costs: $1
Finding 539468 (2024-004)
Significant Deficiency 2024
Special Tests and Provisions Enrollment Reporting – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit find...
Special Tests and Provisions Enrollment Reporting – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College provide additional resources to ensure all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new Standard Operating Procedure (SOP) is being created, which will address enrollment reporting concerns. The Financial Aid office will work with the Registrar to increase communication between offices and eliminate enrollment reporting errors. The Financial Aid office will also improve reporting to the third-party processor, so that timely and accurate information is uploaded to NSLDS. Furthermore, a recurring review of the third-party’s reporting to NSLDS will be instituted. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 6/30/2025
While the audit notes improvements in this area, we continued to face some challenges in properly allocating indirect costs and fringe benefits to individual contracts. We will close the remaining gap between the costs properly billed to individual contracts and the process of reflecting these costs...
While the audit notes improvements in this area, we continued to face some challenges in properly allocating indirect costs and fringe benefits to individual contracts. We will close the remaining gap between the costs properly billed to individual contracts and the process of reflecting these costs in our accounting system by refining our cost allocation plan. This revision will include consistent rules for allocating indirect and fringe plus a quarterly review by accounting staff and management. We will also use newly formatted grant worksheets shared with us by Whittlesey to help us identify and correct any allocation issues before closing out our accounting records for this fiscal year.
AAA will create a worksheet to show unpaid balances and will create A/P transactions for those to be reported on monthly financials. Completion date March 31 st, 2025 by fiscal dept
AAA will create a worksheet to show unpaid balances and will create A/P transactions for those to be reported on monthly financials. Completion date March 31 st, 2025 by fiscal dept
Analysis is provided on a monthly basis by the Chief Financial Officer and the Accounting department. Balance Sheet, Profit & Loss, Cash Flow and A/P Agings are reviewed and provided to the CEO, the BOD Finance Committee and then to all BOD Members. Also provided is an organization dashboard present...
Analysis is provided on a monthly basis by the Chief Financial Officer and the Accounting department. Balance Sheet, Profit & Loss, Cash Flow and A/P Agings are reviewed and provided to the CEO, the BOD Finance Committee and then to all BOD Members. Also provided is an organization dashboard presentation with 12-14 Key Performance Indicators monthly.
Condition: Of the 40 students selected for enrollment reporting testing, 1 student did not have their program-level status change updated appropriately and another student was not updated from less than half time to withdrawn by the University's third party administrator. Planned Corrective Action: ...
Condition: Of the 40 students selected for enrollment reporting testing, 1 student did not have their program-level status change updated appropriately and another student was not updated from less than half time to withdrawn by the University's third party administrator. Planned Corrective Action: Clearinghouse reporting process has been reassessed, and error reporting will be completed weekly. Training will be done for registrar staff on process, and how to verify information has successfully been accepted by NSLDS. The Registrar's office will work closely with Financial Aid to verify enrollment updates and complete error resolution. Contact person responsible for corrective action: Callie Zake, Senior Director Student Financial Services Anticipated Completion Date: June 30, 2025
Recommendation: CLA recommends the University implements a process place to ensure the required reporting is completed in the timeline allowed by the granting agency and to complete any missed or late reporting as required. Explanation of disagreement with audit finding: There is no disagreement wit...
Recommendation: CLA recommends the University implements a process place to ensure the required reporting is completed in the timeline allowed by the granting agency and to complete any missed or late reporting as required. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: St. Thomas identified the applicable FFATA reporting requirements and assigned responsibility to the appropriate party. Name(s) of the contact person(s) responsible for corrective action: Sarah Ervin, sarah.ervin@stthomas.edu Planned completion date for corrective action plan: The additional reporting requirement has been added to the accounting department’s list of responsibilities beginning in January 2025.
Recommendation: CLA recommends the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to fin...
Recommendation: CLA recommends the University review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: By reviewing the ordering of internal processes and procedures St. Thomas determined two internal processes ran out of order causing incorrect reporting. Procedural documentation has been updated and training provided to ensure this error is not repeated. Name(s) of the contact person(s) responsible for corrective action: Yuko Kachinsky: yuko.kachinsky@stthomas.edu Planned completion date for corrective action plan: A process error was identified and corrected in August 2024.
Edit Check Worksheets will be matched to requests for State of NJ Division of Agriculture reimbursement on a monthly basis for accuracy.
Edit Check Worksheets will be matched to requests for State of NJ Division of Agriculture reimbursement on a monthly basis for accuracy.
BREF will ensure that the data collection form and the Single Audit package are filed the earlier of nine (9) months after year end or thirty (30) days after delivery of the financial statements.
BREF will ensure that the data collection form and the Single Audit package are filed the earlier of nine (9) months after year end or thirty (30) days after delivery of the financial statements.
Contact Person: Travis Mickey, Registrar Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding. The College will collaborate with NSC to evaluate the errors in the file transmissions and to develop procedures to minimize further errors in ...
Contact Person: Travis Mickey, Registrar Views of Responsible Officials and Planned Corrective Action: There is no disagreement with the audit finding. The College will collaborate with NSC to evaluate the errors in the file transmissions and to develop procedures to minimize further errors in the future. More specifically, the College will review the reporting procedures for withdrawn and graduating students to ensure the correct information is transmitted to NSLDS. Anticipated Completion Date: 6/30/2025
Finding 539367 (2024-001)
Significant Deficiency 2024
Incorrect Return of Title IV (R2T4) Funds Calculations and Untimely Returns Planned Corrective Action: When this was identified last year, the Director of Financial Aid Office spent the next year working with the Department of Education as they conducted two separate reviews. The first review was c...
Incorrect Return of Title IV (R2T4) Funds Calculations and Untimely Returns Planned Corrective Action: When this was identified last year, the Director of Financial Aid Office spent the next year working with the Department of Education as they conducted two separate reviews. The first review was completed and we were notified that everything was good. The second review recently concluded via an exit interview where we were notified that a final report would be sent to us within the next two months. Additionally, the Director of Financial Aid has been working with the IT department, the Registrar’s Office, and our Academic Technology department to streamline the identification of students who need a R2T4 completed. This has been an ongoing process in the midst of the program reviews and getting clarification and guidance from the Department of Education, coupled with the FAFSA issues, continued to cause further delays with R2T4 calculations. Person Responsible for Corrective Action Plan: Andrea Ruth, Director of Financial Aid Anticipated Date of Completion: 3/22/2025
View Audit 349900 Questioned Costs: $1
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