Corrective Action Plans

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Finding 504301 (2024-006)
Significant Deficiency 2024
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the re...
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937. Recommendation: We recommend the University revise their procedures to include documentation of the review over FFATA reporting. The documentation should include the date of the review and the individual(s) performing the review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We recognize the need to enhance our documentation of internal controls to ensure testability and maintain compliance with federal reporting standards. While our existing internal processes ensured data accuracy, timeliness, and submission compliance, we acknowledge that documentation of the review process is beneficial. Moving forward, the Contract Review Officer (CRO) will review FFATA reports submitted by another team member. When the CRO submits the report, her supervisor or an OSP employee will perform the review. Each review instance will be documented with the reviewer’s name and date to reinforce control transparency and testability, aligning our process more closely with compliance requirements. Name(s) of the contact person(s) responsible for corrective action: Sarah Martonick, Director, Office of Sponsored Programs, 208-885-2145. Planned completion date for corrective action plan: October 31, 2024
Finding 504296 (2024-003)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with aud...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063. Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We created a report to track the timing of reporting disbursements to COD. Currently we load the disbursement record to COD once a week. If there is an issue and the file is rejected it creates issues with timeliness. We have a meeting on 10/9/2024 to evaluate how we want to resolve the issue. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Danial Carlos, and Brady Nelsen. Planned completion date for corrective action plan: December 2024
Finding 504291 (2024-002)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007,84.033. Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported...
Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007,84.033. Recommendation: We recommend that the University work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are adjusting our corrective action. Last year we tested several out of cycle enrollment adjustments each term to ensure our processes were working. We didn’t find any issues. This year we will be comparing all the students were not reported to the Clearinghouse with the list reported to the Clearinghouse to ensure all students who need to be reported are properly reported. Name(s) of the contact person(s) responsible for corrective action: Randi Croyle, Director of Financial Aid. Planned completion date for corrective action plan: We ran our first comparison on 9/19/2024 and we will be running every month we do the Clearinghouse reporting.
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal ...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Perkins Loan Program– Assistance Listing No. 84.038 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Teacher Education Assistance. for College and Higher Education Grants– Assistance Listing No. 84.379 Nursing Student Loans – Assistance Listing No. 93.364 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office took over the administration of this process due to personnel changes in the Registrar’s Office this past year. During this time period, we have reduced the incidents from 114 to 13. Enrollment reports will continue to be submitted monthly. The data is reviewed at various intervals of the process by Registrar and Financial Aid staff and the reviews are documented. Corrections and updates are provided and submitted as required. Procedures will be updated to reflect all changes and validations. Additional focus will be on the reports which overlap semesters. Timelines will be reviewed and adjusted as determined necessary Name(s) of the contact person(s) responsible for corrective action: Laura Hughes, Soo Lee Bruce-Smith, Travis Osburn, Kim Tuschhoff and John Bender Planned completion date for corrective action plan: Immediate Implementation
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being re...
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024
2024-001 Condition: The District did not timely file expenditure reports for all federal awards within the Education Stabilization Fund. Recommendation: The District should timely file all expenditure reports to stay compliant with federal awards. Management Response: The District will take the...
2024-001 Condition: The District did not timely file expenditure reports for all federal awards within the Education Stabilization Fund. Recommendation: The District should timely file all expenditure reports to stay compliant with federal awards. Management Response: The District will take the necessary steps to ensure that expenditure reports are timely filed going forward. Anticipated Date of Completion: June 30, 2025
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being re...
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being re...
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being re...
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2024
The Corporation deposited the surplus cash in the Residual Receipts account as of June 17, 2024
The Corporation deposited the surplus cash in the Residual Receipts account as of June 17, 2024
The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure ...
The University agrees with the auditors' finding and recommendation. The following corrective action will be taken: The University Registrar will adhere to: Provisions of 34 CFR Section 685.309(b) will be followed when reporting to NSLDS. The University will develop and implement controls to ensure students’ classification based on actual allowable credit hours are being properly reported to NSLDS. Unofficial withdrawals will be monitored to ensure timely reporting to NSLDS. The University Registrar will work collaboratively with the Information Technology office to modify the enrollment report to identify students with external credits as well as students who stop attending to allow proper reporting to the NSLDS within the required 30 days. Anticipated Completion Date: December 31, 2024 Leah Stewart, Assistant Vice President, Enrollment Management
2024-002 - Meal Claim Reimbursement Noncompliance Auditor Description of Condition and Effect. One of three meal claim reimbursement reports selected for testing did not agree to underlying meal count sheets. On the one report that did not agree, the District understated claims for all of its facili...
2024-002 - Meal Claim Reimbursement Noncompliance Auditor Description of Condition and Effect. One of three meal claim reimbursement reports selected for testing did not agree to underlying meal count sheets. On the one report that did not agree, the District understated claims for all of its facilities. As a result of this condition, the District submitted inaccurate claims for reimbursement, resulting in a reimbursement less than what the District should have received. Auditor recommendation. We recommend that the District implement a thorough review process of entered data prior to certification of claims data. We also recommend that a secondary review of claims data be done by a District finance department staff to ensure proper claims data. Corrective Action. The District will implement a thorough review process of entered data prior to certification of claims data. The District will also implement a secondary review of claims data that will be done by a District finance department staff to ensure proper claims data. Responsible Person. Michelle Bennin, Chief Financial Officer Anticipated Completion Date. June 30, 2025
Corrective Action Plan - Upon reflection of the term end date and subsequently the status change date, the Office of Registrar at the University of Dallas updated the term end date to the last date of educationally related activities more widely known as the last date of the final examinations for e...
Corrective Action Plan - Upon reflection of the term end date and subsequently the status change date, the Office of Registrar at the University of Dallas updated the term end date to the last date of educationally related activities more widely known as the last date of the final examinations for each relevant term. Upon consultation with the Office of the Provost at the University of Dallas and the appropriate Deans of the affected Colleges, the program length for the Master’s programs at the University of Dallas will be updated to three (3), for those programs who are at least 30 credit hours in length: which will meet a reasonable progression to such degree. The Office of Registrar at the University of Dallas will update all such programs for the University of Dallas. The Office of Registrar and the Office of Financial Aid explored reporting enrollment directly to the National Student Loan Data System and while such was initially promising, the Office of Financial Aid determined that such activity would be disruptive to the business practices of the University of Dallas given the work needed for the Financial Value Transparency and Gainful Employment reporting in which the National Student Loan Clearinghouse has served as an invaluable partner. This option may still be explored further if additional resources become available. The Office of the Registrar at the University of Dallas will split the graduation file sent to our third-party servicer, NSLC, so that the students from the Satish & Yasmin Gupta College of Business who are on a different calendar may be reported to NSLDS sooner which should assist in reporting those students on an earlier timeframe. The Office of Registrar at the University of Dallas will begin rolling grades the week after Add/Drop on a weekly basis of each term to reduce the timeframe for students who have withdrawn from a course to be reported to NSLDS. The Office of the Registrar at the University of Dallas will update the grading policy in Ellucian Banner to align any changes in grading policy for students who fail to attend course. The Office of Financial Aid will work with the Student Registrar to ensure such reporting is accurate by reviewing the set-up of such data points as Enrollment Effective Date, Enrollment Status, Term Begin Date, Term End Date and Award Completion Date. Implementation - The responsible parties include the Office of Registrar - Paula Brown, Registrar, the Office of Financial Aid, James Hubener, Director of Financial Aid, along with the staff of Information Technology led by Karl Horvath at the University of Dallas. Some updates to the status change dates or term end dates have already been recorded. Updates to the program length for Master’s programs will be made by November 2024. Implementation of internal Office of Registrar functions to assist in reporting for changes in grades and enrollment levels should be in place by November 30, 2024. Any change in the processing of the Graduated file from NSLC should be in place by the anticipated date of implementation of February 28, 2025. Full utilization of all changes by May 15, 2025 at the close of the Spring 2025 term.
Finding 504029 (2024-002)
Significant Deficiency 2024
Title: Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with ...
Title: Student Financial Assistance Cluster – Assistance Listing No. 84.063 Recommendation: We recommend the College evaluate its procedures and policies around reporting Pell disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Our office will create formal procedures for the Pell origination/disbursement process to ensure that our dates within the system and COD are aligned. Additionally, our new financial aid management system (FAMS) has the ability to track discrepant dates between COD and our FAMS and we will regularly use this feature to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Danielle Hayden Planned completion date for corrective action plan: November 1, 2024
Finding 504025 (2024-001)
Significant Deficiency 2024
Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disa...
Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.0033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Last year, we developed additional validation steps to ensure that the status of every student who has completed their program and graduated is accurately reflected at both the National Student Clearinghouse and NSLDS. These validation steps improved the accuracy of reporting for students included in the bulk reporting process. I will conduct a comprehensive review of our current reporting procedures to identify any gaps or inefficiencies. An additional staff member will be trained to report individual students to the National Student Clearinghouse in a timely manner, ensuring that any "one-off" updates are promptly completed. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: October 1, 2024
Finding 503949 (2024-001)
Significant Deficiency 2024
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Expl...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Financial aid maintains a log of all Title IV withdrawals, and going forward it will provide access to this log to the Registrar’s Office and will notify the Associate Registrar each time a student is determined to be withdrawn for R2T4 purposes. This will ensure that the Financial Aid Office and the Registrar’s Office are aligned with regard to a student’s Title IV enrollment status. This will be particularly helpful to ensure compliance for students enrolled in modules, where a student could be considered withdrawn for a semester even if their transcript shows that credit was earned for all of their officially attempted credits. This compliance issue was discovered and remediated by Drake prior to the audit as part of our own internal review process. Upon each submission of the graduation data file to the National Student Clearinghouse, the Registrar’s Office will double-check the count of awarded degrees that appear on the submission file and compare it to the number of awarded degrees as reported by Drake’s student information system. Additionally, shortly after each file is submitted to the NSC, the Registrar’s Office will cross-check a sample of JD graduates against both the NSC database and the NSLDS database to ensure that the graduation status for graduates of the JD program is being accepted and processed by the NSC as expected, and that they are in turn properly reported to NSLDS. Name(s) of the contact person(s) responsible for corrective action: Kevin Moenkhaus, Associate Registrar and Brandi Miller, Assistant Director of Financial Aid. Planned completion date for corrective action plan: September 1, 2024.
Management should undertake a review of internal controls over financial reporting and ensure that financial data is properly recorded in the books and records of the project to prevent misstatements from occurring in the future. 2. Management should implement procedures to ensure that required fili...
Management should undertake a review of internal controls over financial reporting and ensure that financial data is properly recorded in the books and records of the project to prevent misstatements from occurring in the future. 2. Management should implement procedures to ensure that required filing is completed timely.
Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350....
Management should establish procedures and monitor compliance with those procedures to ensure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs.
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely...
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely.
Management agrees with the finding and recommendation and has reviewed the HUD requirement for security funding. Funds have been transferred and will be maintained based on HUD requirements in a separate account from operating funds. Move in EIVs - All move in files will be sent to our in house comp...
Management agrees with the finding and recommendation and has reviewed the HUD requirement for security funding. Funds have been transferred and will be maintained based on HUD requirements in a separate account from operating funds. Move in EIVs - All move in files will be sent to our in house compliance department and Franklin Group has an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90 day reminders for all move in. Existing Tenant EIV - It is the policy that all existing tenant EIV and 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The RM is required during monthly visits to spot check at least 5 existing tenants. Gross Rent Change and Medical Reporting - The policy states that all Gross Rent Changes are to be completed as approved by the new rent schedule - The Community Manager is required to scheduled appointments with all residents to sign the effective gross rent change and file in tenants files, it is also required that residents 50059s are signed and in the file, the Community Manager has taken the latest HUD training with our in house HUD Compliance Manager- The Regional Manager will also spot check files to be certain that all Gross Rent Changes are in its 6 part file folders. Medical reporting records were discussed in our HUD Compliance Training and all expenses must be in the 6-part file folder. Again, the RM will continue to spot check files during the monthly required inspections. All HUD Communities were required to participate in the HUD Training as a reminder tool. Security Deposit - Franklin Companies has a policy that all security deposit refunds must be submitted within the 3 days move out period. This situation was due to the changeover in Management.
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely...
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely.
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely...
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely.
Management agrees with the finding. Managements Plan of Action for Non- Compliance of the HUD Guidelines includes the immediate steps below: 1. Provide additional training and resources to ensure that the staff has a clear understanding of HUD requirements that will include the importance of adherin...
Management agrees with the finding. Managements Plan of Action for Non- Compliance of the HUD Guidelines includes the immediate steps below: 1. Provide additional training and resources to ensure that the staff has a clear understanding of HUD requirements that will include the importance of adhering to procedures and guidelines with a specific focus on the EIV requirements and reporting, along with the timely processing of annual recertifications. 2. Implement increased monitoring and oversight mechanisms to detect and correct compliance issues. 3. Establish clear accountability measures for not following procedures through appropriate corrective actions. 4. Effectively communicate the importance of following procedures to all staff, emphasizing the impact on organizational efficiency and compliance. 5. Encourage a culture of continuous improvement where procedures are regularly reviewed, communicated with the staff and provide regular training of changing circumstances or best practices.
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely...
1. Management agrees with the finding and recommendation and has implemented reviews of the financial statements by senior management prior to closing books to ensure accuracy of information. 2. Management agrees with the finding and recommendation and will ensure required filing is completed timely.
Management agrees with the finding and has implemented the below policies and will continue to train, and connect our team members with the in house HUD Compliance Specialist for support. 1. Move in EIV's - All move in files will be sent to our in house compliance department and Franklin Group has a...
Management agrees with the finding and has implemented the below policies and will continue to train, and connect our team members with the in house HUD Compliance Specialist for support. 1. Move in EIV's - All move in files will be sent to our in house compliance department and Franklin Group has an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90 day reminders for all move in. 2. Existing Tenant EIV - It is the policy that all existing tenant EIV & 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The RM is required during monthly visits to spot check at least 5 existing tenants. 3. Gross Rent Change & Medical Reporting - The policy states that all Gross Rent Changes are to be completed as approved by the new rent schedule - The Community Manager is required to scheduled appointments with all residents to sign the effective gross rent change and file in tenants files, it is also required that residents 50059s are signed and in the file, the Community Manager has taken the latest HUD training with our in house HUD Compliance Manager- The Regional Manager will also spot check files to be certain that all Gross Rent Changes are in it's 6 part file folders. Medical reporting records were discussed in our HUD Compliance Training and all expenses must be in the 6-part file folder. Again, the RM will continue to spot check files during the monthly required inspections. All HUD Communities were required to participate in the HUD Training as a reminder tool. 4. Security Deposit - Franklin Companies has a policy that all security deposit refunds must be submitted within the 3 days move out period. This situation was due to the changeover in Management.
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