Corrective Action Plans

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The University will strengthen internal controls and monitoring processes to ensure compliance with Title IV credit balance regulations. Specific corrective actions include: 1. Implementing a weekly audit of credit balances within the student financial system to identify and initiate refund process ...
The University will strengthen internal controls and monitoring processes to ensure compliance with Title IV credit balance regulations. Specific corrective actions include: 1. Implementing a weekly audit of credit balances within the student financial system to identify and initiate refund process when a Title IV credit balance exceeds the allowable time frame. 2. Providing and accessing additional training to financial aid and student accounts personnel on Title IV regulations regarding credit balances and timely refunds. 3. Establishing a formalized procedure for escalating unresolved balances to senior financial administrators for immediate corrective action.
View Audit 351424 Questioned Costs: $1
Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office and will establish a working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, ...
Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office and will establish a working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, reporting frequency, and other “upstream” preventative measures that may be taken to prevent file backlogs. Internally, the University will establish formalized communication protocols between departments to be enacted in the case of an NSC enrollment reporting file delay that could result in noncompliance with enrollment reporting requirements. Regent University will establish a reporting process directly between the University and NSLDS to be used in the event of an NSC backlog that cannot be mitigated within the compliance window. Regent University will implement the first and second parts of this plan by June 30, 2025 and the final component (NSLDS direct file reporting process) by September 30, 2025. Name of responsible parties: Elizabeth Bayless (University Registrar) & Tameka Lyons (Associate Registrar)
FINDING 2024-005 Finding Subject:. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and ex...
FINDING 2024-005 Finding Subject:. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period, the School Corporation was required to submit five annual data reports as outlined below. Fund Applicable Reporting Period ESSER I July 1, 2021 – June 30, 2022 ESSER II July 1, 2021 – June 30, 2022 ESSER III July 1, 2021 – June 30, 2022 ESSER II July 1, 2022 – June 30, 2023 ESSER III July 1, 2022 – June 30, 2023 All five annual data reports were selected for testing. Two of the five annual data reports did not include the correct expenditure information. Specifically the ESSER II and ESSER III annual data reports with an applicable reporting period of July 1, 2022, to June 30, 2023, did not include expenditure data for this period. Instead, the annual reports incorrectly reported expenditures from the previous period of July 1, 2021 to June 30, 2022. Contact Person Responsible for Corrective Action: Greg Elkins, CFO Contact Phone Number and Email Address: (317) 485-3100, greg.elkins@mvcsc.k12.in.us Views of Responsible Officials: We agree with the finding. Description of Corrective Action Plan: Since the conclusion of the 2020-2022 SBOA audit, the CFO and Corporation Treasurer have archived numerous email threads and other evidence of communication which documents the process for pulling ESSER financial data from the Skyward Finance system and submitting the required reports. This documentation shows the CFO and Treasurer regularly communicating, checking and rechecking the data, and verifying the timely submission of that data. The school received periodic requests from the Indiana Department of Education, Office of Federal Grants asking it to submit financial data for all ESSER funds. Originally, the data requests were submitted through JotForms which do not have the capability of notifying any individuals other than the recipient. The school was required to create its own documents for proof of submission and did so. In subsequent requests, IDOE provided Excel spreadsheets to be completed and returned electronically. Those emails and spreadsheets have been curated by the school. The school has documented unclear instructions provided by IDOE, the pass through agency. The school accepts responsibility to report grant activity for the federally required reporting periods regardless. The school will ask for explicit instructions from IDOE and reconfirm the reporting data required and time period(s) in question. This additional layer of internal controls will be added to the process currently utilized by the CFO and Corporation Treasurer. The school has not expended any dollars from any ESSER fund since 2023. Anticipated Completion Date: TBD based on when the next reporting submission is requested by IDOE (all ESSER grants activities have ceased and the funds have been closed out locally.)
Finding 547016 (2024-001)
Significant Deficiency 2024
Audit Finding Reference: 2024-001 Improve Internal Controls Over Reporting Planned Corrective Action: All future ARPA reporting will be derived from quarterly trial balances generated from the accounting department staff. The trial balances will then be reviewed and entered into the reporting por...
Audit Finding Reference: 2024-001 Improve Internal Controls Over Reporting Planned Corrective Action: All future ARPA reporting will be derived from quarterly trial balances generated from the accounting department staff. The trial balances will then be reviewed and entered into the reporting portal by the Finance Director. Any variances or adjustments that are necessary from the Trial balance will be clearly documented for reconciliation and confirmed by the City Auditor as accurate. Upon confirmation, the Finance Director will submit the report. Planned Implementation Date of Corrective Action: Quarter 1, 2025 report (due by April 30th, 2025) Person Responsible for Corrective Action: City Auditor Finance Director
To address the increase in the Organization’s activities under this program, the Certified Management Accountant of Weavers Way Community Fund, Inc. will send a performance report to the Department of Housing and Urban Development.
To address the increase in the Organization’s activities under this program, the Certified Management Accountant of Weavers Way Community Fund, Inc. will send a performance report to the Department of Housing and Urban Development.
FINDING 2024-006 Finding Subject: Education Stabilization Fund--Reporting Contact Person Responsible for Corrective Action: Andrew McDaniel, Chief Financial and Operations Officer Contact Phone Number and Email Address: 260.894.3191 and mcdaniela@westnoble.k12.in.us Views of Responsible Officials: W...
FINDING 2024-006 Finding Subject: Education Stabilization Fund--Reporting Contact Person Responsible for Corrective Action: Andrew McDaniel, Chief Financial and Operations Officer Contact Phone Number and Email Address: 260.894.3191 and mcdaniela@westnoble.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Chief Financial Operations Officer will prepare the reports and have the Curriculum Director review for accuracy. Anticipated Completion Date: July 1, 2026
Northern Tier Community Action concurs with the audit finding. The Organization did not timely reconcile and submit the Program reporting in accordance with the requirements set forth by the grantor Agency. The Organization has reviewed the existing reporting policies and procedures to ensure they...
Northern Tier Community Action concurs with the audit finding. The Organization did not timely reconcile and submit the Program reporting in accordance with the requirements set forth by the grantor Agency. The Organization has reviewed the existing reporting policies and procedures to ensure they are in line with the grantor Agency’s requirements and that they clearly define timelines, roles and responsibilities. The Organization has also implemented controls to ensure that we are in compliance with all guidelines set forth by the grantor Agency. Northern Tier Community Action Corporation has implemented the above controls as of the report date.
COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2024 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accorda...
COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2024 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Interim Finance Director Phone: (787) 788-0404 Original Finding Number: 2024-004 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: Objective of the plan: The objective of this Corrective Action Plan is to address the observations identified in the audit and establish preventive measures to avoid future recurrences. Corrective Actions: 1. Schedule restructuring: • Create a detailed calendar with clear dates to define intermediate delivery deadlines to avoid delays (collection of information, analysis, writing, review, and submission) 2. Implementation of alerts and reminders: • Set up automatic alerts and email reminders for key dates (for example, 3 days before each deadline) 3. Review and Quality Control: Establish an internal review of reports before final submission to ensure that the information reported is accurate and complete. The revision includes compliance with the requirements established by the agency. Compliance Monitoring: • Biweekly meetings: The team will have biweekly meetings to have updates regarding the progress and achievement of the deadlines. • Email notifications: Emails will be sent to document the timely submission of reports and when needed, waivers will be requested explaining situations that may have delayed the process to prepare accurate and complete reports on time. Evaluation: • Monthly evaluations will be performed to measure the compliance of the submission of the reports on the timeframe established by the agency. • Adjustments to the processes according to the response of the team. Implementation Date: March 2025 Responsible persons: • Person responsible for the implementation: Mrs. Erika J. Acevedo, Program Accountant • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director
COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2024 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accorda...
COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2024 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2023 – June 30, 2024 Fiscal Year: 2023-2024 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Interim Finance Director Phone: (787) 788-0404 Original Finding Number: 2024-003 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: Objective of the plan: The objective of this Corrective Action Plan is to address the observations identified in the audit and establish preventive measures to avoid future recurrences. Corrective Actions: 1. Schedule restructuring: • Create a detailed calendar with clear dates to define intermediate delivery deadlines to avoid delays (collection of information, analysis, writing, review, and submission) 2. Implementation of alerts and reminders: • Set up automatic alerts and email reminders for key dates (for example, 3 days before each deadline) 3. Review and Quality Control: Establish an internal review of reports before final submission to ensure that the information reported is accurate and complete. The revision includes compliance with the requirements established by the agency. Compliance Monitoring: • Biweekly meetings: The team will have biweekly meetings to have updates regarding the progress and achievement of the deadlines. • Email notifications: Emails will be sent to document the timely submission of reports and when needed, waivers will be requested explaining situations that may have delayed the process to prepare accurate and complete reports on time. Evaluation: • Monthly evaluations will be performed to measure the compliance of the submission of the reports on the timeframe established by the agency. • Adjustments to the processes according to the response of the team. Implementation Date: March 2025 Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director
Action taken in response to finding: Program managers will continue working to ensure that all FAFTA forms are appropriately reported in SAM.gov Name(s) of the contact person(s) responsible for corrective action: Sharon Cullins, Community Development Planner, and Lara Kritzer, Director of Housing a...
Action taken in response to finding: Program managers will continue working to ensure that all FAFTA forms are appropriately reported in SAM.gov Name(s) of the contact person(s) responsible for corrective action: Sharon Cullins, Community Development Planner, and Lara Kritzer, Director of Housing and Community Development. Planned completion date for corrective action plan: This will be implemented immediately.
Action taken in response to finding: The September 2023 claiming error was caused in part by the Food Service Management Company manually entering the claims in the DESE Portal incorrectly. Newton took responsibility for entering the claims for the balance of FY24. For FY25, Newton now uploads the...
Action taken in response to finding: The September 2023 claiming error was caused in part by the Food Service Management Company manually entering the claims in the DESE Portal incorrectly. Newton took responsibility for entering the claims for the balance of FY24. For FY25, Newton now uploads the meal count data from Mosaic, the point-of-sale software, directly into the DESE portal. That upload is done by the Business Operations Analyst and then approved by the Director of Business Operations, which removes substantial exposure for human error during data entry and creates two levels of review prior to approval and submission. The other five discrepancies between the source counts and what was submitted for the DESE claim was to address identified human error in advance to ensure that the monthly claim was accurate. For the September 2023 error, Newton has submitted a Claim Adjustment Form to DESE to provide guidance for the necessary action steps. Name(s) of the contact person(s) responsible for corrective action: Amy Mistrot, NPS Director of Business Operations. Planned completion date for corrective action plan: The internal controls to reduce data entry errors have been implemented and are consistently being used. DESE will provide guidance for the Claim Adjustment Request to address the September 2023 error, which Newton will then implement.
View Audit 351352 Questioned Costs: $1
Oversight of Internal Controls - Completeness and Existence of Federal Expenditures Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will implement a...
Oversight of Internal Controls - Completeness and Existence of Federal Expenditures Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will implement a centralized, documented review process for all federal expenditure tracking. To address turnover-related gaps and avoid data inconsistency: o Internally prepared spreadsheets will be reconciled monthly and locked once reviewed o All federal award-related spreadsheets will be reviewed by a staff member other than the preparer o Changes to prior-year data will require approval and documentation o A documented checklist will be used for month-end reconciliations. Additionally, the Business Manager will oversee staff training on federal compliance requirements related to documentation and review processes.
Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will establish formal written policies and...
Preparation of Schedule of Expenditures of Federal Awards Type of Finding: Material Weakness in Internal Control over Financial Reporting/ Compliance • Contact Person Responsible: Frank Antuono, Business Manager • Corrective Action to be Taken: The District will establish formal written policies and procedures for the preparation of the Schedule of Expenditures of Federal Awards (SEFA) in compliance with 2 CFR 200.51 0(a). These procedures will: o Identify all sources of federal revenue o We have added the assigned federal funding source codes to our district budget operation in CSIU, which will now allow us to track these expenditures back to our internally controlled spreadsheets as verification of expenditures. o Track expenditures using dedicated account codes in the general ledger o Assign responsibility for monthly reconciliation and schedule preparation o Include a secondary review of the SEFA by someone other than the preparer The Business Office will undergo training on SEFA requirements and reconciliation practices. These changes will ensure complete and accurate reporting of federal expenditures for all future reporting periods.
Finding 546965 (2024-003)
Significant Deficiency 2024
Enrollment information was not submitted accurately or within the required timeframe by the University. Personnel Responsible for Corrective Action: Margaret Herron, Registrar. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2025. Corrective Action Plan: Managemen...
Enrollment information was not submitted accurately or within the required timeframe by the University. Personnel Responsible for Corrective Action: Margaret Herron, Registrar. Anticipated Completion Date: Corrective action plan will be implemented by June 30, 2025. Corrective Action Plan: Management has provided training and the financial aid department will make regular updates to NSLDS on a monthly basis to ensure student information is reported accurately and timely.
Finding Number: 2024-001 Condition: The Organization failed to submit monthly reimbursement requests to the Hebrew Immigrant Aid Society by their due dates during the year ended June 30, 2024. Planned Corrective Action: The Organization has implemented system and process improvements to ensure tim...
Finding Number: 2024-001 Condition: The Organization failed to submit monthly reimbursement requests to the Hebrew Immigrant Aid Society by their due dates during the year ended June 30, 2024. Planned Corrective Action: The Organization has implemented system and process improvements to ensure timely submission. The Organization has and will continue to maintain appropriate staffing level and sufficient training to ensure timely submission. This plan does not account for circumstances beyond JFS’s control such as timing of funding approval from the grantor. Non-controllable delays will be documented by JFS and reports submitted in a reasonable amount of time following approval. Contact Person Responsible for Corrective Action: Justin Fisher, Director of Accounting Anticipated Completion Date: April 30, 2025
Santa Fe Community College respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the n...
Santa Fe Community College respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS III – Federal Award Findings 2024-001 – Compliance Requirements Over Reporting-Fiscal Operations Report and Application to Participate (FISAP) (Other Non-Compliance) Responsible Party: Nick Telles – Vice President of Finance and Jacob Pacheco – Chief Financial Officer and Financial Aid Director. Corrective Action Plan: Management concurs with this finding. Preliminary FISAP was entered into the Campus Based System (CBS) in order to perform built-in validation checks in CBA. The erroneous data was based on a Banner-generated FISAP report dated 8/21/2024. The final FISAP data was entered using a Banner reported generated 09/26/2024 but the field referenced within the finding were not entered when finalizing the data. Institutions are allowed to make corrections to the FISAP until December 15th each calendar year. Once identified, the corrections were submitted on 10/24/2024. Anticipated Completion Date: June 30, 2025 If there are any questions regarding this plan, please call Nick Telles at 505-428-1161 or email at nick.telles@sfcc.edu or Jacob Pacheco at 505-428-1814 or email at jacob.pacheco@sfcc.edu.
Finding 2024-006 – Allowable Costs/Cost Principles Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: With recent personnel changes, project managers with adequate knowledge of allowable costs are responsible for tracking all costs. In collabor...
Finding 2024-006 – Allowable Costs/Cost Principles Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: With recent personnel changes, project managers with adequate knowledge of allowable costs are responsible for tracking all costs. In collaboration with the Treasury Department, new internal controls have been implemented, ensuring clear and effective tracking methods are maintained and practiced regularly. Proposed Completion Date: June 30, 2025
View Audit 351336 Questioned Costs: $1
Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: Due to personnel changes, obtaining authorization to access the reporting site proved to be a challenging and time-consuming process. To prevent similar issues in the future, a cross-training pr...
Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: Due to personnel changes, obtaining authorization to access the reporting site proved to be a challenging and time-consuming process. To prevent similar issues in the future, a cross-training program and centralized task list are being developed to ensure multiple staff members are familiar with all tasks and have backup access to logins when available. Proposed Completion Date: June 30, 2025
Finding 546953 (2024-001)
Significant Deficiency 2024
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS within the required sixty-day time period. Explanation of disagreement with audit findin...
NSLDS Reporting Recommendation: We recommend the Institution review its reporting procedures to ensure that students’ program begin dates and program enrollment effective dates are accurately reported to NSLDS within the required sixty-day time period. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Furman University added additional enrollment reporting dates in April and July to address the identified over 60-day gap. Specifically, we have incorporated two new reporting dates in April 2025 and July 2025. These dates are now part of our reporting schedule for the 2024-25 academic year and will continue to be included in the transmission schedule moving forward. Additionally, the University Registrar will provide the Senior Associate Director of Financial Aid with the annual enrollment reporting dates at the beginning of each academic year to ensure ongoing compliance. Name(s) of the contact person(s) responsible for corrective action: James Patton and Melissa Barnette Planned completion date for corrective action plan: 08/26/2024
Corrective Action Plan: 1. Enhanced Review Process o A biweekly reconciliation process is implemented where payroll charges are compared against the certified time and effort reports before submission for posting of grant funded payroll (updated Standard Operating Process on record). o The Grant Acc...
Corrective Action Plan: 1. Enhanced Review Process o A biweekly reconciliation process is implemented where payroll charges are compared against the certified time and effort reports before submission for posting of grant funded payroll (updated Standard Operating Process on record). o The Grant Accountant will conduct a review to verify allocations align with the time and effort reports. o The Director of Grants Management will conduct a second review of the allocations to verify that allocations align with the time and effort reports before the report is sent to the Business Office for posting in the accounting system. 2. Monitoring and Compliance Checks o The Grants Management office will conduct quarterly internal audits of grant payroll allocations to verify compliance with grant requirements. By implementing these corrective actions, the College ensures that grant funded personnel profiles and associated expenses are accurately recorded to federal grant programs and prevent similar errors in the future. Timeline for Implementation of Corrective Action Plan: Implementation of the biweekly reconciliation process was completed in February 2025. Contact Person Agnes Simon, Senior Director of Grants Management
View Audit 351324 Questioned Costs: $1
Corrective Action Plan: Funds for the student referenced were transferred to COD on 5/4/2024, 2 days after disbursement. During this timeframe, there were significant communication errors between the US DOE, the SAIG mailbox and institutions including Bunker Hill Community College due to the impleme...
Corrective Action Plan: Funds for the student referenced were transferred to COD on 5/4/2024, 2 days after disbursement. During this timeframe, there were significant communication errors between the US DOE, the SAIG mailbox and institutions including Bunker Hill Community College due to the implementation of FAFSA simplification. The rejected file was found during monthly reconciliation and resolved on 6/3/2024. To prevent this type of error from happening again, Bunker Hill has moved to a bi-weekly review of the PRER Pell discrepancy report in Colleague. While we feel that this error is largely due to circumstances surrounding the challenges with FAFSA simplification, this additional bi-weekly review will prevent any possible reoccurrence of late reporting. Timeline for Implementation of Corrective Action Plan: Effective immediately Contact Person Jillian Glaze, Senior Director of Student Financial Services
Embry-Riddle Aeronautical University Corrective Action Plan Single Audit - Fiscal Year Ending 2024 Finding: 2024-001 Federal Program: Federal Direct Student Loans (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Name(s) of the contact person(s) responsible for corrective action: • Julie Ferguson...
Embry-Riddle Aeronautical University Corrective Action Plan Single Audit - Fiscal Year Ending 2024 Finding: 2024-001 Federal Program: Federal Direct Student Loans (ALN 84.268) Federal Pell Grant Program (ALN 84.063) Name(s) of the contact person(s) responsible for corrective action: • Julie Ferguson, University Registrar • Edward Trombley, Registrar, Worldwide Campus • Ria Woods White, Senior Associate Registrar, Residential Campuses • Scott Johnson, Associate Registrar, University Registrar Office View of Responsible Officials: Registrar leadership agree with the audit finding and will implement additional review procedures to ensure that enrollment and graduate records are submitted to the National Student Loan Data System (NSLDS) in a timely and accurate manner. Corrective Action Plan: Action Anticipated Completion Date Institute periodic internal reviews to ensure that the enrollment and graduation reporting process meet required standards. Ongoing Operationalize a duplicative review process for Worldwide enrollment and graduation report submissions. Ongoing
Condition During our reporting test, we detected reports that were submitted after the corresponding biweekly period. In addition, the expenditures in the reports contained errors of reporting related to the amounts for employee retentions for payroll taxes, which were included in the reports but ar...
Condition During our reporting test, we detected reports that were submitted after the corresponding biweekly period. In addition, the expenditures in the reports contained errors of reporting related to the amounts for employee retentions for payroll taxes, which were included in the reports but are not expenditures incurred by the Organization. Views of Responsible Officials and Corrective Actions Justification: The organization acknowledges that four (4) out of twenty-four (24) bi-weekly reports for ALN 21.027 were submitted late. The report due September 1, 2023, was submitted on September 6, 2023. This delay was due to an unintentional error involving a mismatch of dates, as explained in an email to the grantor on the same day as the submission. The grantor acknowledged receipt of the report. Furthermore, the organization maintains continuous communication with the grantor to validate eligible expenses. The grantor has not verbalized any major discrepancies related to late submissions in the monthly stakeholder meetings due to our continuous communication with the grantor. While the organization recognizes the late submission, it asserts that the delay was minor and promptly addressed. Root Cause Analysis and Immediate Corrective Actions: • Objective: Identify underlying causes of late submissions and report errors. o Conduct interviews with staff involved in reporting processes. o Review workflow for report preparation, approval, and submission. o Analyze gaps in understanding compliance requirements (e.g., misclassification of FICA/Medicare retentions). Corrective Actions: The organization has taken steps to improve internal controls and prevent future late submissions. To address and prevent the issues identified in Finding No. 2024-001, the following corrective actions are the following: Establish Formalized Oversight and Monitoring: ● Implement a system of checks and balances for report preparation and submission. ● Designate specific personnel responsible for reviewing reports before submission to ensure accuracy and timeliness. ● Develop a tracking mechanism (e.g., a checklist or calendar) to monitor report deadlines and submission status. Enhance Internal Controls: ● Develop and document written policies and procedures for the bi-weekly reporting process. This documentation should clearly outline: ○ Report preparation guidelines, following 2 CFR 200.302. ○ Data sources and required supporting documentation, following 2 CFR 200.300. ○ Review and approval processes, following 2 CFR 200.303. ○ Submission deadlines and methods, following grantor requirements and 2 CFR 200.343. ● Provide training for staff responsible for preparing and submitting reports, emphasizing the importance of accuracy and adherence to deadlines, following 2 CFR 200.303. ● Implement a process for regular reconciliation of report data with underlying financial records to ensure accuracy, following 2 CFR 200.302. Improve Report Accuracy: ● Clearly define what constitutes an allowable expenditure for the federal program, in accordance with 2 CFR Part 200 Subpart E. ● Provide specific guidance and examples to staff to prevent the inclusion of non-expenditure items (like employee payroll tax retentions) in reports. ● Implement automated checks or validation rules in the reporting process to detect and prevent errors. ● Conduct pre-submission audits by a compliance officer to review expenditures against federal guidelines, including OMB Circular A-133. ● Develop a retroactive correction protocol to address past errors, including communication with the grantor if amendments are Timely Submission of Reports: ● Implement a system of reminders for report deadlines. ● Establish clear consequences for failing to submit reports on time. ● Evaluate the current reporting timeline and assess if adjustments are needed to ensure timely submission. Communication with Grantor: ● Proactively communicate with the grantor regarding the corrective actions being taken to address the findings. ● Provide the grantor with a timeline for implementation of these actions. By implementing these corrective actions, Sociedad para Asistencia Legal de Puerto Rico, Inc. can improve the accuracy and timeliness of its bi-weekly reporting, ensure compliance with federal requirements, and mitigate the risk of penalties or other adverse actions. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor A. Díaz Pomales - Director de Finanzas Anticipated Completion Date: March 26, 2025
Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective a deficiency in the submission of enrollment data to the Clearinghouse. In April 2024 after t...
Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective a deficiency in the submission of enrollment data to the Clearinghouse. In April 2024 after the 2023 audit, we identified there were issues with how our enrollment reporting was being submitted to the Clearinghouse. Unfortunately, these 2023-2024 findings occurred prior to the implementation of new process and timing of our Enrollment reporting since these results of the 2022-2023 audit. The Registrar updated their process to ensure the reporting date parameters are being reported correctly and that the last date of attendance is pulled into the fields needing to be reported to the National Student Loan Data System (NSLDS) as the Effective Date. Enrollment reporting is being reported more frequently and is submitted at the start of each term, subsequently within the term, and at the end of the term to ensure reporting timelines are met and that the withdrawal date and effective date match for reporting purposes. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Waqas Mirza, Registrar: Waqas.Mirza@urbancollege.edu
Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of a lack of understanding of procedures involved in posting and reporting to COD. In April...
Corrective Action The Urban College of Boston (UCB) agrees with this finding, and upon its review of the affected students and the college’s policies and procedures, has determined the errors are reflective of a lack of understanding of procedures involved in posting and reporting to COD. In April 2024 after the 2023 audit, we identified this as a gap in the Business Office process to ensure that dates disbursed matched the COD system. This process was rectified, and the business office staff was coached and trained. Unfortunately, these 2023-2024 findings occurred prior to the implementation and coaching of these new processes. Urban College of Boston (UCB) has contracted with Global Financial Aid Services (Global FAS) effective for the 2023/2024 Award Year. Global FAS provides UCB with a monthly reconciliation report through our shared Secured File Transfer Protocol site (SFTP)and notifies us when one is ready to be reviewed. Once the file is received, the Business Office will conduct a secondary reconciliation using the Global FAS report. The Business Office will review the students ledger/billing and compare information with COD to ensure all disbursement information matches according to regulation. Urban College conducted a full reconstruction of COD dates to Ledger posting dates and ensured that all dates for this auditing period and current funding year disbursements are accurate. Urban College has also moved to a once-a-week disbursement schedule which will structure our reporting from our SIS system to COD and assist in the accuracy of our data review. Global Financial Services has been conducting a quarterly testing of our disbursement records to also ensure the accuracy of data. The Director of Financial Aid and Chief Finance Officer will continue to review procedures and update according to regulation and policy changes so potential gaps are discovered proactively. Timeline for Implementation of Corrective Action Plan: Although categorized as a repeat finding, Urban College considers this year’s issue an extension of the original finding from the 2023 audit period. This is because the corrective action plan addressing the initial finding was not implemented until April 2024, after the conclusion of the 2023 audit. Furthermore, all the students involved in this year’s finding were enrolled before the corrective action plan was rolled out in April 2024. Contact Person: Stacy Broadus, Director of Student Financial Services: Stacy.Broadus@urbancollege.edu
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