Corrective Action Plans

Finding 547381 (2024-002)

None 2024

PR

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

UCB recognizes its obligation to report enrollment data to the National Student Loan Data System (NSLDS) at least every 60 days. The Registrar's Office reports enrollment data to NSLDS on a monthly basis. To ensure that the University complies with the 60-day requirement, we have established an addi...

UCB recognizes its obligation to report enrollment data to the National Student Loan Data System (NSLDS) at least every 60 days. The Registrar's Office reports enrollment data to NSLDS on a monthly basis. To ensure that the University complies with the 60-day requirement, we have established an additional notification procedure. The Financial Aid Office will forward a report of all Title IV student recipients classified as withdrawn to the Registrar's Office, this process consists of a reconciliation of the data. The Registrar's Office will report the enrollment change of these cases to NSLDS within 60 days required. Anticipated completion date: Immediately.

View Audit 351630

Finding 547378 (2024-002)

Significant Deficiency 2024

Baltimore County, Maryland

MD

Subrecipient Monitoring Reporting Significant Deficiency § 200.303 § 200.332 § 200.501

COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing Number 21.027 Recommendation: The County should review and enhance internal controls and procedures to ensure that evaluation of independent audits is performed. Explanation of disagreement with audit finding: There ...

COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing Number 21.027 Recommendation: The County should review and enhance internal controls and procedures to ensure that evaluation of independent audits is performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Division of Grants Management will require annual reports and audits from all SLFRF subrecipients. If a subrecipient does not meet the criteria for a annual audit, support for that conclusion will be maintained in each Grantee file. Name(s) of the contact person(s) responsible for corrective action: Elizabeth Meadows Planned completion date for corrective action plan: June 2025

View Audit 351628

Finding 547374 (2024-001)

None 2024

Thiel College

PA

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2024 Criterion: Title IV regulations (34 CFR 685.309b) require t...

Federal Program: Student Financial Assistance Cluster - Federal Direct Student Loan Program Federal Agency: U.S. Department of Education Pass-Through Entity: Not applicable Assistance Listing Number: 84.268 Federal Award Year: June 30, 2024 Criterion: Title IV regulations (34 CFR 685.309b) require that upon receipt of an enrollment report from the Secretary, Institutions must update all information included in the report and return the report to the Secretary; (i) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, an Institution must notify the Secretary within 30 days after the date the Institution discover that: (i) 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 Institution 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; or (ii) a student who is enrolled at the Institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition and Context: For four students out of twenty-five selected for testing, the College did not notify the NSLDS in a timely matter of a change in enrollment status. Cause and Effect: The College failed to follow its procedures for reporting student status changes. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate in NSLDS. Recommendation: The College should implement a process and related to verify with NSLDS that all enrollment status information for all students is updated accurately and timely. Corrective Action Plan The College will continue to work with the NSC Audit Response Team, Office of the Registrar, and Office of Information Technology to resolve the data reporting issues we are currently experiencing. Denise Owens, Student Loan Specialist and Debbie Schreiber, Registrar will work together to provide manual data reporting to NSLDS in an accurate and timely manner. Responsible Persons Scott Allen, Interim Director of Financial Aid Denise Owens, Student Loan Specialist Debbie Schreiber, Registrar Anticipated Completion Date This is an ongoing process and will begin immediately

View Audit 351625

Finding 547360 (2024-002)

Significant Deficiency 2024

Roof Above, Inc.

NC

Subrecipient Monitoring Reporting Significant Deficiency

Corrective Action Plan Reporting – Reporting Finding 2024-002 Roof Above will develop a policy for formal documentation of review of required reports prior to submission, including retention of this report. Roof Above will also comply with reporting requirements as outlined in grant agreements. Cont...

Corrective Action Plan Reporting – Reporting Finding 2024-002 Roof Above will develop a policy for formal documentation of review of required reports prior to submission, including retention of this report. Roof Above will also comply with reporting requirements as outlined in grant agreements. Contact person responsible for corrective action: Kaedon Grinnell, Chief Program Officer Anticipated completion date: December 31, 2024

View Audit 351621

Finding 547359 (2024-007)

Material Weakness 2024

Puerto Rico Safe Drinking Water Treatment Revolving Loan Fund

PR

Reporting Subrecipient Monitoring

PRDH agrees with the finding. In this case there were three (3) more reports submitted for extension to the federal government, however, with this particular report the PRDH did not receive an answer. However, we have procedures in place in order to meet the reporting requirements to all federal pro...

PRDH agrees with the finding. In this case there were three (3) more reports submitted for extension to the federal government, however, with this particular report the PRDH did not receive an answer. However, we have procedures in place in order to meet the reporting requirements to all federal programs be submitted on time. The PRDH is working with the Division of External Resources (Federal Program) to establish and strengthen our internal controls to ensure all federal reports comply with the guidelines established by the Federal Government.

View Audit 351620

Finding 547357 (2024-003)

Material Weakness 2024

Puerto Rico Safe Drinking Water Treatment Revolving Loan Fund

PR

Matching / Level of Effort / Earmarking Material Weakness Reporting

PRDOH agrees with the finding. PRDOH has fixed the segregation of financial record, we already have the system in place in People Soft 8.4 in which permit the tracing of the funds to the level of expenditures that will be adequate.

View Audit 351620

Finding 547321 (2024-005)

Material Weakness 2024

Mount St. Mary's University

MD

Student Financial Aid Material Weakness Reporting

Identifying Number: 2024-005 – Special Tests – Enrollment Reporting Finding: Student status changes were not reported accurately to NSLDS. The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to th...

Identifying Number: 2024-005 – Special Tests – Enrollment Reporting Finding: Student status changes were not reported accurately to NSLDS. The audit team noted that the University does not appear to have a control in place to identify in a timely manner inaccurate information that was provided to the NSLDS by their third party servicer. Corrective Actions Taken or Planned: We agree with the auditors’ findings. NSLDS receives enrollment data from MSMU through the National Student Clearinghouse (NSC). If a student who was previously reported as enrolled is not listed subsequently, NSC will report the student as withdrawn. If MSMU does not update the records on a timely basis, NSC automatically reports to NSLDS that the student has withdrawn, which may not be the case. The errors in the reporting process have been resolved and the appropriate steps are in place to report on a timely basis. Person(s) Responsible for Correction Actions: Boyd Creasman, Provost Anticipated Completion Date: April 30, 2025

View Audit 351604

Finding 547313 (2024-002)

Significant Deficiency 2024

California Baptist University

CA

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

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The University has added an additional audit report to be run prior to submis...

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment and program information is accurately reported to NSLDS as required by regulations. Action taken in response to finding: The University has added an additional audit report to be run prior to submission of enrollment reports to Clearinghouse and NSLDS. The report will audit for a change in the reported program begin date between reports when the reported program has not changed. The report inaccurate program begin dates calculated by our Student Information System as a result of a code update sent out by the vendor. Names of the contact persons responsible for corrective action: Shawnn Palmer, Director of Academic Technology and Reporting Planned completion date for corrective action plan: As of March 19, 2025, the student record in the finding has already been corrected. The additional audit report is in draft and will be validated prior to the April reporting.

View Audit 351603

Finding 547298 (2024-002)

Material Weakness 2024

Rising Sun - Ohio County Community School Corporation

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description...

FINDING 2024-002 Finding Subject: COVID-19 – Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Kelli Keith Contact Phone Number and Email Address: 812-438-2655, kkeith@risingsun.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the criteria for the reporting is changed forcing us to change our answers, we will keep better notes of what we changed, and why we changed it. Our final numbers were correct, and we spent the money out of the correct categories. Jennifer Mossburger, Title I coordinator, and I worked together on this reporting. We will continue to work together on the reporting for the federal grants. However, we will do a better job of documenting our work. Anticipated Completion Date: 3/3/2025

View Audit 351598

Finding 547277 (2024-012)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Corrective Action Plan: The University experienced changes with the Student Support Services program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation and reporting methods weren’t available due to the transit...

Corrective Action Plan: The University experienced changes with the Student Support Services program personnel. This change led to a loss of institutional knowledge, interrupted policy and process enforcement. In many instances documentation and reporting methods weren’t available due to the transition of key program personnel. Information that appears to be inaccurate serves as a combination of the inability to make revisions for previously reported students and human error. The CMC principal investigator for CMC was a first-time awardee, who was not fully acclimated to the grant reporting process prior to submitting the report. The Student Support Services program is committed to implementing continuous monitoring of program records to ensure compliance with federal, institutional, and program requirements. The program will review the existing program operating procedures and processes to align with requirements. Program personnel will engage in professional development opportunities and training to improve grant management. Currently, financial reporting is reviewed by individuals in both the Business Office and GSPAR. GSPAR will enhance its internal controls, policies, and procedures to ensure that all reporting is submitted with accurate information. GSPAR intends to create a centralized location to track and store all supporting documentation for easy access and review. GSPAR also intends to require that all financial information required by government agencies be reviewed by officials in both the Business and GSPAR Offices. In addition, GSPAR will implement a process for continuous monitoring of program records to ensure compliance with federal, Institutional and program requirements. The program staff will also engage in professional development opportunities to improve grant management and regulatory compliance. Anticipated Completion Date: December 31, 2025

View Audit 351580

Finding 547259 (2024-006)

Significant Deficiency 2024

Johnson C. Smith University

NC

Student Financial Aid Eligibility Reporting

Corrective Action Plan: A lack of systematic communication between the Registrar’s Office and the Office of Financial Aid, coupled with an absence of an established process flow or calendar to guide quality assurance activities, led to these discrepancies. The University understands that accurate re...

Corrective Action Plan: A lack of systematic communication between the Registrar’s Office and the Office of Financial Aid, coupled with an absence of an established process flow or calendar to guide quality assurance activities, led to these discrepancies. The University understands that accurate reporting of student enrollment status is crucial for managing student eligibility for federal financial aid, including loans and grants; however, in these cases, there were several discrepancies. The University underwent a re-organization the resulted in the creation of a new division, Strategic Enrollment and Retention Management (“SERM”), effective February 2025. SERM aims to address the root causes of this finding by fostering enhanced synergy and communication between the Registrar’s Office and the Office of Financial Aid. This structural change aligns both departments under the governance of the Senior Vice President, ensuring cohesive and compliant operational practices. The alignment will facilitate a unified approach to meet federal reporting requirements more effectively and efficiently, thereby enhancing our administrative capability and compliance with critical federal requirements. This proactive governance restructuring is expected to significantly improve our process accuracy and compliance integrity, safeguarding our students' financial interests and maintaining our standing with federal financial aid programs. In addition, the University will establish audit and verification processes that involve conducting an exhaustive audit of current enrollment reporting processes in collaboration with Financial Aid Services (FAS) to identify and amend discrepancies. We will implement comprehensive, quarterly training for all staff involved in enrollment reporting starting August 2025 to ensure adherence to federal regulations. The Registrar’s Office will establish bi-weekly reporting schedules to the National Student Clearinghouse (NSC), including during summer terms, to ensure timely updates in NSLDS. There will also be regular review sessions to evaluate the effectiveness of the new reporting protocols and make necessary adjustments. Anticipated Completion Date: August 31, 2025

View Audit 351580

Finding 547250 (2024-003)

Significant Deficiency 2024

Johnson C. Smith University

NC

Internal Control / Segregation of Duties Student Financial Aid Reporting

Corrective Action Plan: The verification for one student was improperly conducted, leading to financial aid awards and disbursements based on unverified or incorrectly verified financial data, specifically regarding untaxed IRA distributions and pensions. The verification failure was due to an overs...

Corrective Action Plan: The verification for one student was improperly conducted, leading to financial aid awards and disbursements based on unverified or incorrectly verified financial data, specifically regarding untaxed IRA distributions and pensions. The verification failure was due to an oversight by the aid administrator who incorrectly verified the untaxed IRA distribution and pension as zero, despite contradictory evidence or a lack of supporting documentation. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. Resulting from the work of FAS, the verification policies will be thoroughly reviewed, and revised, to ensure comprehensive coverage as mandated by federal regulations. The University will also establish a robust quality control system to regularly review verification practices and compliance, ensuring adherence to updated policies. We will update and maintain a verification checklist that includes all data elements required for verification. This checklist will be used in all verifications, with a secondary review and sign-off by another trained administrator to ensure accuracy and completeness. In addition, we will bolster training for all financial aid staff, utilizing resources from FAS and the National Association of Student Financial Aid Administrators (NASFAA) to deepen understanding and expertise in verification processes. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547248 (2024-002)

Significant Deficiency 2024

Johnson C. Smith University

NC

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

Corrective Action Plan: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS syste...

Corrective Action Plan: The inaccuracies stemmed from insufficient workflow integration among the Office of Financial Aid and the Registrar’ Office. A critical lack of scheduled checks failed to align submission or processing dates. Furthermore, technical issues between Jenzabar and PowerFAIDS systems contributed to erroneous COA budgets. The University partnered with Financial Aid Services (“FAS”) in February 2025 to review the current systems and process, and devise appropriate systems, checks, and balances to address each deficiency in our financial aid processes and personnel. In addition, as part of the University’s transition of its ERP system from Jenzabar to Colleague, Financial Aid will be transition from the use of PowerFaids to Ellucian Colleague for financial aid management. Resulting from the work of FAS, the University will institute a systematic monthly reconciliation process to ensure consistency across all systems (COD, PowerFAIDS, Jenzabar and Colleague). This includes matching COA and disbursement records to ensure accuracy. To optimize workflow, we will establish a comprehensive calendar of disbursement and reporting deadlines, with routine internal audits every 30 days, starting April 2025. This measure will enforce accountability and timeliness in reporting. We will enhance integration between financial systems (Jenzabar and PowerFAIDS) to prevent data mismatches and streamline the reporting process. In addition, we will leverage our partnership with FAS to conduct regular training sessions for staff across the Financial Aid, Registrar, and Finance Offices to ensure everyone is aware of compliance requirements and system functionalities. These training sessions will start May 2025. Anticipated Completion Date: September 30, 2025

View Audit 351580

Finding 547232 (2024-001)

Significant Deficiency 2024

The University of Charleston, INC

WV

Reporting Student Financial Aid

The University recognizes the untimely staff turnover and the impact it has had on University compliance. University leadership has taken steps to ensure immediate and future compliance with the regulations referenced in this finding. The following corrective action plan has been implemented to prev...

The University recognizes the untimely staff turnover and the impact it has had on University compliance. University leadership has taken steps to ensure immediate and future compliance with the regulations referenced in this finding. The following corrective action plan has been implemented to prevent delays in future reporting. An experienced Institutional Researcher (IR) has been hired for the University, with over 20 years of student enrollment data management and reporting to the National Student Clearinghouse (Clearinghouse). The schedule for reporting student enrollment has been modified to reflect reporting within 30-to-45-day intervals. Reporting at this interval will ensure compliance with the 60-day requirement. Email notifications of enrollment reports due, enrollment reports submitted, correction reports, and report delinquencies from the Clearinghouse are now sent to the IR, the Registrar, and the Provost’s Office. The Provost and the IR meet at least weekly regarding compliance and ongoing reporting for the University.

View Audit 351564

Finding 547230 (2024-001)

Significant Deficiency 2024

Puerto Rico Safe Drinking Water Treatment Revolving Loan Fund

PR

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding No. 2024-001 -Allowable Activities-Loans repayments Condition Found Principal and interest have not been collected from the Revolving Fund on projects that were completed since before the execution of the loan agreement, which are included as part of the financial agreement dated September 2...

Finding No. 2024-001 -Allowable Activities-Loans repayments Condition Found Principal and interest have not been collected from the Revolving Fund on projects that were completed since before the execution of the loan agreement, which are included as part of the financial agreement dated September 2, 2022. Therefore, repayment of principal and payment of interest should have begun on their respective dates, as set forth in the loan agreement and notes payable executed thereto. Views of Responsible Officials and Corrective Action Plan Once the final inspection of a construction project is performed, DOH will submit notifications to PRASA requesting the Notice of Substantial Completion letter from PRASA concurring that the project is acceptable of the operation. Such letter will be an attachment to the formal notification that DOH will send to PRASA and PRIFA. DOH’s letter will specify the starting operating date and the useful life of the project. Therefore, PRIFA will be in position to collect principal and interest for the project according to federal regulations and as established in the loan agreement. Name (s) of the Contact Person (s) Responsible for Corrective Action Ángel Pantoja Rodríguez, Secretary of the Treasury Department, Eduardo Rivera Cruz, Executive Director Puerto Rico Infrastructure Financing Authority and Victor Ramos, Secretary of the Puerto Rico Department of Health. Anticipated Completion Date Immediately

View Audit 351563

Finding 547217 (2024-013)

Material Weakness 2024

Huntington County Community School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

FINDING 2024-013 Finding Subject: COVID 19-Education Stabilization Fund-Reporting Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We ...

FINDING 2024-013 Finding Subject: COVID 19-Education Stabilization Fund-Reporting Contact Person Responsible for Corrective Action: Alexandria Eckert/Tyler Haskough Contact Phone Number: 260-356-8312 Email Address: aeckert@hccsc.k12.in.us/thaskough@hccsc.k12.in.us Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: Huntington County Community School Corporation will establish an Internal Control Standards manual by July 1, 2025, along with the Segregation of Duties chart by August 1, 2025. These standards will include items that detail the procedures and processes along with the checks and balances needed to ensure proper oversight, prevention, detection, correction, or errors. Our process will also ensure reporting compliance is followed. The Internal Control Standards manual will include special tests and provisions. To ensure accuracy and efficiency, future reporting will be prepared by the grant administrator, reviewed by the Grants Specialist then approved by the Corporation Treasurer or Chief Operating Officer before submission. Anticipated Completion Date: Huntington County Community School Corporation will establish the Internal Control Standards by July 1, 2025, and train administration and staff in August 2025.

View Audit 351544

Finding 547171 (2024-003)

Material Weakness 2024

Asian University for Women (auw) Support Foundation

MA

Subrecipient Monitoring Reporting

Finding 2024-003: Subrecipient Monitoring Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management notes the items on finding 2024-002 also applies to this item. Nonetheless the management will implement train...

Finding 2024-003: Subrecipient Monitoring Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management notes the items on finding 2024-002 also applies to this item. Nonetheless the management will implement training on relevant Asian University for Women (AUW) program personnel in the area of Federal Funding Accountability and Transparency Act (FFATA). All such training of relevant personnel is planned to be completed by December 31, 2025.

View Audit 351526

Finding 547169 (2024-001)

Material Weakness 2024

Washington and Lee University

VA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan to Finding 2024‐001: Contact person for corrective action: Melissa Neal, Registrar Correction Action Plan: The University plans to implement the following: During the 2024‐2025 academic year, the Registrar Office will implement the following mechanisms to ensure that all statu...

Corrective Action Plan to Finding 2024‐001: Contact person for corrective action: Melissa Neal, Registrar Correction Action Plan: The University plans to implement the following: During the 2024‐2025 academic year, the Registrar Office will implement the following mechanisms to ensure that all status change records are reported to NLSDS accurately.  Reinforce training of individuals in the compliance and control ownership roles to ensure controls are operating as designed.  Ensure that individuals in compliance and control ownership roles within the Registrar’s office validated that enrollment files submitted were processed in the correct sequence.

View Audit 351524

Finding 547165 (2024-006)

Significant Deficiency 2024

Georgetown College

KY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Perkins Loan Program, 84.038 Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work Study Program, 84.033 Criteria: The College is required to comply with 34 CFR Section 674.19, 34 CFR 675....

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Perkins Loan Program, 84.038 Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work Study Program, 84.033 Criteria: The College is required to comply with 34 CFR Section 674.19, 34 CFR 675.19 and 34 CFR 676.19. Condition: During our testing of the Fiscal Operations Report and Application to Participate (FISAP), we noted that Part II (Application), Section E, Line 22: total tuition and fees for the award year July 1, 2023 to June 30, 2024 did not agree or reconcile to the statement of activities. Cause: The College did not have controls in place to ensure FISAP reporting was accurate. Effect: The College did not follow federal regulations regarding FISAP reporting accuracy. The provisions of 34 CFR Section 674.19, 34 CFR 675.19 and 34 CFR 676.19 were not followed and thus the total tuition and fees for the award year July 1, 2023 to June 30, 2024 reported on the FISAP were greater than the tuition and fees on the statement of activities by $368,034. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: We recommend that the College implement a control to ensure FISAP reporting is accurate. Corrective Actions Taken or Planned: The College concurs with the finding. A system of controls will be implemented to ensure accurate data is reported on all required reporting. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: August 2025

View Audit 351511

Finding 547163 (2024-004)

Significant Deficiency 2024

Georgetown College

KY

Student Financial Aid Eligibility Reporting

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a)(2). Condition: During our testing of eligibility, we selected 40 samples and noted three instances wher...

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.304(a)(2). Condition: During our testing of eligibility, we selected 40 samples and noted three instances where the loan disbursement date on the student's leger did not agree to the disbursement date on Common Origination and Disbursement (COD). Cause: The College did not have controls in place to properly review COD disbursement dates to verify all students had proper reporting to COD. Effect: The College did not follow federal regulations regarding reporting to COD. The provisions of 34 CFR Section 685.301(a)(2) were not followed and thus three students loans were improperly reported to COD. Questioned Costs: There are no questioned costs associated with this finding. Recommendation: We recommend that the College review all COD disbursements and perform monthly COD reconciliations by student to verify the disbursement date and amount matches the student ledger. Corrective Action Taken or Planned: The College concurs with the finding. Controls have already been implemented to ensure accurate and timely reporting to COD. Individual Responsible for Corrective Action: Katie Palmer, Director of Financial Planning Expected Completion Date: November 2024

View Audit 351511

Finding 547161 (2024-002)

Significant Deficiency 2024

Georgetown College

KY

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.309(b ). Condition: During our testing of eligibility, official withdraws, and student status changes for grad...

Federal Program: U.S. Department of Education - Student Financial Assistance Cluster Federal Direct Loan Program, 84.268 Criteria: The College is required to comply with 34 CFR Section 685.309(b ). Condition: During our testing of eligibility, official withdraws, and student status changes for graduates, we selected 40, one, and 21 samples, respectively. We noted three instances in eligibility testing, one instance in official withdraws, and one instance in student status change for graduates where a student's status changes were either not reported timely or accurately to the National Student Loan Database System (NSLDS). Cause: The College did not have controls in place to ensure student's classification were being properly reported to the NSLDS. Effect: Student status changes were not reported within the required timeframe under federal regulations. The provisions of 34 CFR Section 685.309(b) were not followed and thus two students were not reported and subsequently not placed into loan repayment status in a timely manner. Questioned Costs: There were no questioned costs associated with this finding. Recommendation: We recommend that the College implement a control to ensure data is being reviewed for accuracy by the appropriate personnel before roster files are submitted to NSLDS. In addition, we recommend that the College submit roster files on a regular basis. Corrective Actions Taken or Planned: The College concurs with the finding. The Registrar's Office will implement a system of reviews and controls that ensure timely and accurate reporting of student status changes to the National Student Loan System (NSLDS). Individual Responsible for Correction Action: Katie Palmer, Director of Financial Planning Expected Completion Date: August 2025

View Audit 351511

Finding 547115 (2024-002)

Significant Deficiency 2024

Vmsn, Inc.

NV

Reporting § 200.303

Finding 2024-002 – Compliance and Internal Control Systems Over Compliance, Reporting (SEFA): Management Response: Management acknowledges the finding regarding the inconsistent use of the accrual basis of accounting for federal grant reimbursements. At the time of SEFA preparation, the methodology ...

Finding 2024-002 – Compliance and Internal Control Systems Over Compliance, Reporting (SEFA): Management Response: Management acknowledges the finding regarding the inconsistent use of the accrual basis of accounting for federal grant reimbursements. At the time of SEFA preparation, the methodology used was based on the reimbursement requests submitted throughout the year, which had been prepared on a cash basis. However, for the final reimbursement under the City of Las Vegas grant ending June 30, 2024, accrued payroll costs for work performed in June but paid in July were included to ensure full reporting of eligible grant activity. This deviation from the previously applied basis led to the noted inconsistency. Planned Corrective Actions: Going forward, management will implement the following corrective actions: • A consistent accounting basis (accrual) will be selected and formally documented for all SEFA reporting and federal reimbursement requests. • Internal procedures will be updated to reflect the chosen basis and ensure it is applied uniformly across all reimbursement submissions. • A secondary review of SEFA reporting will be conducted by senior finance staff or the CEO to ensure consistency with the selected accounting method. • Staff will be trained annually on SEFA requirements and federal compliance standards under 2 CFR 200. These corrective actions will be completed by June 30, 2025.

View Audit 351486

Finding 547101 (2024-002)

Material Weakness 2024

Kids' Harbor, INC

MO

Reporting

Views of responsible officials and planned corrective actions: The Board believes it has personnel who possess suitable skill, knowledge, or experience to oversee services the auditor provides in assisting with financial statement presentation which requires a lower level of technical knowledge tha...

Views of responsible officials and planned corrective actions: The Board believes it has personnel who possess suitable skill, knowledge, or experience to oversee services the auditor provides in assisting with financial statement presentation which requires a lower level of technical knowledge than the competence required to prepare the financial statements, related footnote disclosures and SEFA in accordance with the modified cash basis of accounting.

View Audit 351453

Finding 547091 (2024-003)

Significant Deficiency 2024

Alverno College

WI

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

Condition The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NS...

Condition The College is responsible for designing, implementing, and maintaining internal control over compliance for special tests and provisions and for accurately reporting significant data elements under the Campus-Level and Program-Level records within the National Student Loan Data System (NSLDS) that the Department of Education (ED) considers high risk. Corrective Action Plan Corrective Action Planned: The Registrar will pull a sample of students from the Clearinghouse enrollment update or change submissions to ensure NSLDS has been updated to reflect changes within the 60-day window. Name(s) of Contact Person(s) Responsible for Corrective Action: Marlene Neises, Executive Director for Institutional Effectiveness and Sponsored Programs; and David Brzeczkowski, Controller. Anticipated Completion Date: This will be completed by June 30, 2025.

View Audit 351446

Finding 547079 (2024-001)

Significant Deficiency 2024

Alverno College

WI

Reporting Internal Control / Segregation of Duties

Condition The College’s internal controls over compliance requirements over reporting were not operating effectively in 2024 as the College could not provide timely populations that reconciled to the Schedule of Federal and State Awards (SEFA). Management provided multiple population listings during...

Condition The College’s internal controls over compliance requirements over reporting were not operating effectively in 2024 as the College could not provide timely populations that reconciled to the Schedule of Federal and State Awards (SEFA). Management provided multiple population listings during the audit process. Corrective Action Plan Corrective Action Planned: Monthly reconciliations for Federal and State awards will be finalized and submitted to Enrollment Services and the Finance Department on a timely basis. These reconciliations will include COD screenshots, monthly spreadsheets of all funding reconciliations and supporting documentation. Name(s) of Contact Person(s) Responsible for Corrective Action: Naomi Coe, Financial Aid Director; Mariana Sanabria, VP for Enrollment Services; David Brzeczkowski, Controller. Anticipated Completion Date: This corrective action has been established and will continue monthly. The final balancing of funds for the audit will be completed by July 31st of each year.

View Audit 351446

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