Corrective Action Plans

Finding 552703 (2024-012)

Significant Deficiency 2024

DC

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.430

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

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

View Audit 352153

Finding 551549 (2024-008)

Significant Deficiency 2024

The Howard University

DC

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

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

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

View Audit 352153

Finding 551543 (2024-003)

Significant Deficiency 2024

The Howard University

DC

Student Financial Aid Special Tests & Provisions Reporting

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

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

View Audit 352153

Finding 551537 (2024-006)

Significant Deficiency 2024

The Howard University

DC

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

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

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

View Audit 352153

Finding 551531 (2024-001)

Significant Deficiency 2024

Alameda Health Consortium

CA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

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

View Audit 352145

Finding 551525 (2024-002)

Material Weakness 2024

Pontifical Catholic University of Puerto Rico

PR

Reporting

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

View Audit 352134

Finding 551513 (2024-002)

None 2024

St. Thomas University Inc.

FL

Questioned Costs Student Financial Aid Reporting

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

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

View Audit 352117 Questioned Costs: $1

Finding 551510 (2024-002)

Significant Deficiency 2024

Homeless Assistance Leadership Organization, Inc.

WI

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

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

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

View Audit 352116

Finding 551509 (2024-002)

None 2024

Valor Christian College

OH

Special Tests & Provisions Reporting Internal Control / Segregation of Duties

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

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

View Audit 352114

Finding 551505 (2024-002)

Material Weakness 2024

Clarkson University

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

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

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

View Audit 352112

Finding 551503 (2024-005)

Significant Deficiency 2024

South Carolina State University

SC

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

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

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

View Audit 352110

Finding 551493 (2024-001)

Significant Deficiency 2024

South Carolina State University

SC

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring § 200.303

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

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

View Audit 352110

Finding 551444 (2024-006)

Significant Deficiency 2024

Volunteers of America Western Washington and Subsidiary

WA

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

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

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

View Audit 352105

Finding 551393 (2024-005)

Material Weakness 2024

Hampton University

VA

Eligibility Reporting Matching / Level of Effort / Earmarking

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

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

View Audit 352091

Finding 551391 (2024-004)

Material Weakness 2024

Hampton University

VA

Student Financial Aid Special Tests & Provisions Reporting

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

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

View Audit 352091

Finding 551186 (2024-002)

Significant Deficiency 2024

The City of New York

NY

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

Finding No. 2024-002 Department(s): New York City Department of Health and Mental Hygiene Program(s): Assistance Listing Number 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Corrective Action(s): DOHMH agrees with the recommendation that “DOHMH enhance their internal ...

Finding No. 2024-002 Department(s): New York City Department of Health and Mental Hygiene Program(s): Assistance Listing Number 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Corrective Action(s): DOHMH agrees with the recommendation that “DOHMH enhance their internal controls over the reporting process by ensuring that all financial and special performance reports undergo documented review and approval before submission within the required timeframe.” Anticipated Completion Date: Effective Immediately; 3/25/2025 Person(s) Responsible for Implementation: Yuming Li - Director, yli@health.nyc.gov Anthony Faciane - Assistant Commissioner, afaciane@health.nyc.gov Wai Ting Yu - Assistant Commissioner, wyu4@health.nyc.gov Jennifer Carmona - Senior Director, jcarmona@health.nyc.gov Xiu Mei Mai - Director, xmai@health.nyc.gov James Chan - Director, jchan6@health.nyc.gov Yulia Gudzinskiy - Grants Manager, ygudzinskiy@health.nyc.gov Jenny Tejada - Director, jtejada@health.nyc.gov Inna Dubrovenska - Assistant Director, idubrovenska@health.nyc.gov

View Audit 352075

Finding 551182 (2024-001)

None 2024

The City of New York

NY

Reporting

Finding No. 2024-001 Department(s): New York City Department of Education Program(s): Assistance Listing Numbers: 84.010, Title I Grants to Local Educational Agencies 84.287, Twenty-First Century Community Learning Center 84.365, English Language Acquisition Grants 84.367, Supporting Effective In...

Finding No. 2024-001 Department(s): New York City Department of Education Program(s): Assistance Listing Numbers: 84.010, Title I Grants to Local Educational Agencies 84.287, Twenty-First Century Community Learning Center 84.365, English Language Acquisition Grants 84.367, Supporting Effective Instruction State Grant Corrective Action(s): The DOE continues to recognize the importance of fiscal reporting requirements and has developed and maintains processes and procedures to monitor grant award programs with respect to the timely submission of Final Expenditure Reports (“FS-10F”). Previous efforts to provide additional reporting to field staff were hampered by the hiring freeze and staff turnover. The DOE reviews programs/schools throughout the award period and re-enforces established reporting guidelines to facilitate timely submission of expenditure reports. The DOE continues to closely track grant expenditures throughout and after the grant period, monitoring programs/schools to facilitate accurate and complete records, as well as work with appropriate State Education officials to facilitate the completion and submission of financial expenditure reports. The DOE has incorporated applicable deadlines related to encumbrances and payment certifications into the Fiscal 2024 close calendar in an effort to continue to reinforce the need for the timely payment and takedown of open encumbrances. This message is regularly stressed at close meetings and through e-mails to applicable parties throughout the course of the close process. With respect to the audit finding, the DOE will reemphasize the importance of closing applicable transactions to facilitate timely submission of FS-10F reports. Anticipated Completion Date: Ongoing Person(s) Responsible for Implementation: Barry Elkayam, Executive Director, Office of Revenue Operations (718) 935-5050

View Audit 352075

Finding 551178 (2024-005)

Material Weakness 2024

The City of New York

NY

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

Finding No. 2024-005 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Pro...

Finding No. 2024-005 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): During the COVID 19 pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. HPD continues to make progress in addressing this substantial backlog through the implementation of technological and streamlined program improvements. HPD increased its HUD reporting rate of actions taken on household cases by 34% from FY23. Although there has been significant progress towards on time recertifications, HPD anticipates it will continue to take time until the agency achieves pre-pandemic overall submission levels as HPD ensures that any enforcement action the agency takes is taken as a last resort. HPD’s COVID-era policies involving adverse action have ceased and normal processes are in effect. However, it takes intensive tracking and follow up to ensure participants comply with requirements to submit annual certifications or have due-process before terminating subsidy for failing to respond. As a result, there is a lag between the re-implementation of HPD’s policy to take enforcement actions and ensuring every active participant has a completed certification. 1. Continue to build on existing systems to more closely track recertifications that are mailed and not returned. 2. Build on the more robust digital operations that were started during the pandemic to track the submission of documents improving reporting capabilities that help track overdue recertifications. 3. Create a streamlined process for referring overdue cases for Community Based Organizations that can assist participants complete and return recertification package 4. Continue to provide automated reminders for participants at risk of termination of assistance because of their failure to submit a recertification package. 5. Invest in a training team to meet the training needs of new staff Anticipated Completion Date: Implemented as of March 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 352075

Finding 551172 (2024-001)

Significant Deficiency 2024

Mercy College

NY

Student Financial Aid Reporting Eligibility

Corrective action: There is a process in Banner that creates a file containing graduates for degree verification submission to the National Student Clearinghouse. There was a systematic error with that process in Spring 2024 rendering the process unable to generate a file. The error was not resolved...

Corrective action: There is a process in Banner that creates a file containing graduates for degree verification submission to the National Student Clearinghouse. There was a systematic error with that process in Spring 2024 rendering the process unable to generate a file. The error was not resolved until May 2024, which is when the submission for these students was completed. This was a one-time specific system failure occurrence which has been resolved and the process has been working correctly since May 2024. The Offices of the Registrar and Student Financial Services are working in conjunction with the University compliance team and Office of Institutional Research to enhance review and checks/balances of reporting deadlines to ensure that files are submitted within the required deadlines. Further, the Office of the Registrar will work with internal IT staff to research and implement backup reporting procedures for creating enrollment and graduation files in the event of another system issue. Proposed Completion Date: May 31, 2024

View Audit 352071

Finding 551167 (2024-006)

Significant Deficiency 2024

Bastyr University

WA

Student Financial Aid Reporting

The University should take steps to ensure that its procedures to submit enrollment information to NSLDS in a timely manner are strictly followed.

View Audit 352068

Finding 551141 (2024-001)

Significant Deficiency 2024

Bergen Community College

NJ

Special Tests & Provisions Student Financial Aid Reporting

Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College inter...

Views of Responsible Officials: The College has noted that this finding may not align with the unique nature of our summer session, which has three terms included. There are four non-standard summer terms that do not follow the same reporting structure as the Fall and Spring Terms. The College interprets the 60-day reporting requirement to apply to the standard terms for Fall and Spring only. Historically, the college has reported summer enrollments in August, which has been treated as compliant by the Clearinghouse. However, after further review, the College will adjust its reporting schedule to align with recommendations from this finding. This adjustment will ensure that summer reporting aligns with the 60-day timeframe that is consistent with the Fall and Spring terms.

View Audit 352065

Finding 551125 (2024-003)

Material Weakness 2024

County of Solano

CA

Subrecipient Monitoring Reporting Material Weakness § 200.303

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Housing Voucher Cluster Federal Assistance Listing Number: 14.871, 14.879 Pass‐through: n/a – direct award Award No. and Year: CA131, 2023/2024 Compliance Requirement: Reporting Type of Finding: Material Weakness in In...

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Housing Voucher Cluster Federal Assistance Listing Number: 14.871, 14.879 Pass‐through: n/a – direct award Award No. and Year: CA131, 2023/2024 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials and Corrective Action Plan: Since May 2022, the County has contacted multiple agencies trying to report through the FSRS system on the multiple Housing Voucher awards, with no success. The County’s assigned Housing and Urban Development (HUD) office is the San Francisco regional office. Per their director, “These are systems that we don’t work with in HUD PIH so I won’t be able to be of assistance relative to this.” The County is unable to complete FFATA reporting for reasons outside of the County’s control. Responsible Individual(s): James Bezek, Director of Resources Management Anticipated Completion Date: Because the corrective action is outside of the County’s control, we cannot determine an anticipated completion date.

View Audit 352056

Finding 551122 (2024-001)

Significant Deficiency 2024

Molloy College

NY

Student Financial Aid Special Tests & Provisions Reporting

Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal dat...

Name of contact person responsible for corrective action: Marguerite Lane, Associate Vice President Enrollment Management Mlane@molloy.edu 516-323-4014 Corrective action: Molloy University understands the finding and has devised a process to ensure that the correct withdrawal date is recorded National Student Loan Data System (NSLDS) with the 60-day window from the date of determination. In the finding, the withdrawals were reported within the window, but the effective dates reported were incorrect. We identified the issue and made the corrections, but the corrections were made outside the 60-day window. To address this, we will utilize our current practice of relying on error reports to address such errors, but we will run these reports at an increased frequency (bi-weekly) and have an additional staff member review the information. We will keep a file for each student withdrawal to show that our dates align in our system, the National Student Clearinghouse, and NSLDS within the required timeframe. Proposed Completion Date: March 31, 2025

View Audit 352050

Finding 551121 (2024-002)

Significant Deficiency 2024

Calaveras County Water District

CA

Reporting Significant Deficiency § 200.502

Finding 2024-002 – Significant Deficiency Award No.: 97.036, Disaster Grants-Public Assistance (Presidentially Declared Disasters) Federal Grantor: U.S. Department of Homeland Security, Federal Emergency Management Agency, Passed-through California Governor’s Office of Emergency Services, FEMA-...

Finding 2024-002 – Significant Deficiency Award No.: 97.036, Disaster Grants-Public Assistance (Presidentially Declared Disasters) Federal Grantor: U.S. Department of Homeland Security, Federal Emergency Management Agency, Passed-through California Governor’s Office of Emergency Services, FEMA-4683-DR-CA Compliance Requirement: Other compliance requirements. Condition: The schedule of Expenditures of Federal Awards (SEFA) was not complete, and expenditures reported on the SEFA were revised during the single audit. Criteria: 2 CFR Part 200, Subpart F (Uniform Guidance) Section 200.502 states, “The auditee should prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee’s financial statements.” Internal controls over the SEFA should be in place ensure accrual basis expenses incurred under the federal program are properly reported as expenses on the SEFA and are properly reported as revenue in the financial statements prior to the start of the single audit. Cause: SEFA was not fully reconciled and finalized until after the single audit began. Effect: The expenses included on the SEFA for program 97.036, Disaster Grants-Public Assistance (Presidentially Declared Disasters), program FEMA-4683-DR-CA, were revised during the single audit and questioned costs in the amount of $131,195 were identified, which could have resulted in the auditor not selecting the correct major program or expenses for testing and could have resulted in the single audit not satisfying the requirements of the Uniform Guidance. Context: The District provided cost estimates to the California Governor’s Office of Emergency Services (CalOES) for the amount of flood damage expenses incurred for FEMA Project 725590 and 710830 that were used by CalOES to reimburse the District. The District did not adequately reconcile the expenses incurred at year-end to expense reports available in the accounting system and did not revise the expense estimates provided to CalOES to the actual amounts incurred during the year, resulting in CalOES overpaying the District and the District using the estimated costs on the SEFA for the single audit. Recommendation: We recommend additional review procedures be implemented to ensure the SEFA is complete and accurate when the single audit begins, which includes reconciling all expenses incurred under each federal award down to the invoice, payroll check and lowest level of other costs claimed, cutting-off each expense at year-end and claiming the reconciled qualifying expenses within 45 days after each quarter end. At year-end, programs should be reviewed for cost adjustments, extensions, and other changes that should be reflected on the SEFA when reconciling expenses for the SEFA. Separate program codes should be used for each grant on the SEFA that summarizes expenses down to the individual invoice level that should be provided to the auditor for the single audit. If overclaimed amounts are identified, the grantor and/or pass-though agency should be contacted to determine whether to return the funds or apply the overclaimed amounts to future claims. Views of Responsible Officials and Planned Corrective Actions: The District will implement a formal reconciliation process to ensure all expenditures incurred under each federal award are accurately recorded before the start of the single audit. A quarterly reconciliation process will be conducted after each quarter-end to review and adjust expenses as necessary. The District will contact FEMA to determine whether the questioned costs may be applied to a future claim or whether the amount needs to be returned to FEMA. Estimated Completion Date of Corrective Action: October 1, 2025

View Audit 352048

Finding 551113 (2024-002)

Material Weakness 2024

City of Rancho Cordova

CA

Reporting Internal Control / Segregation of Duties § 200.303

Program/Cluster: Disaster Grants – Public Assistance Federal Financial Assistance Listing Number: 97.036 Federal Grantor: U.S. Department of Federal Emergency Management Agency Pass-through: California Governor’s Office of Emergency Services Award Year: 2024 Grant Award Number: FEMA-4683-DR-CA Comp...

Program/Cluster: Disaster Grants – Public Assistance Federal Financial Assistance Listing Number: 97.036 Federal Grantor: U.S. Department of Federal Emergency Management Agency Pass-through: California Governor’s Office of Emergency Services Award Year: 2024 Grant Award Number: FEMA-4683-DR-CA Compliance Requirement: P – Other Information Management’s Response: We concur. Views of Responsible Officials and Corrective Action: The noncompliance resulted from staff managing these records not being fully aware of the FEMA program compliance supplement that states expenditures are to be reported on the SEFA once they are approved and obligated. The City of Rancho Cordova will implement the following corrective actions: • Ensure all relevant personnel within the city are aware of FEMA’s specific documentation requirements. • Review and revise internal procedures to strengthen controls over grant expenditures to include documentation that supports the status of FEMA’s review of the eligible project cost • Implement a tracking system to ensure all future expenditures have been both approved and obligated by FEMA prior to being included on the SEFA, regardless of the year in which the expenditure was incurred. These measures will ensure that all future costs claimed are allowable, approvals properly supported, and in full compliance with FEMA regulations. Name of Responsible Person: Kim Juran, Administrative Services Director Projected Implementation Date: January 1, 2025

View Audit 352034

Corrective Action Plans

Filters