Corrective Action Plans

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Condition - The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan - A second person compares the meal counts in the claim to the daily meal count reports. The re...
Condition - The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan - A second person compares the meal counts in the claim to the daily meal count reports. The reviewer will then sign and date both the meal count reports (prior to submission) and a printed copy of the meal claim (after submission). Anticipated Date of Completion - June 30, 2026; Name of Contact Person - Dr. Eric Heath, Superintendent; Management Response - A corrective action plan will be developed and implemented. A secondary review of the meal claim to the supporting documents will be performed before the meal claim is submitted.
Recommendation: The University should review its policies and procedures around COD reporting to ensure students’ information is reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Imp...
Recommendation: The University should review its policies and procedures around COD reporting to ensure students’ information is reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Implementation of a monthly process where the Associate Director of Financial Aid Technical Operations will pull and review, on the 15th of each month, the Pell Reconciliation Report from the Common Origination and Disbursement (COD) website to ensure timely and accurate reporting to COD regarding Pell disbursements. • In addition to the Pell Reconciliation Report, the School Account Statement (SAS) would then be shared with the Disbursement Accounting Manager in Accounts Payable to compare their internal student disbursement records with the U.S. Department of Education’s official data, ensuring funds drawn down match those awarded. • This process will ensure that disbursement reviews occur more frequently and within the 15-day window from any given disbursements. It will also help identify discrepancies in student Pell Grant and Direct Loan amounts to maintain compliance and provide a consistent approach that minimizes risk of error or delay in disbursements. Name(s) of the contact person(s) responsible for corrective action: Leida Nieves, Executive Director of Financial Aid Services Planned completion date for corrective action plan: June 30, 2026
2025-001 Student Financial Aid Cluster – Assistance Listing Numbers 84.063 and 84.268 In general, Cheyney University continues its trajectory of cross-functional and interrelated institutional improvements, particularly those impacting the National Student Loan Data System (NSLDS) that is reported t...
2025-001 Student Financial Aid Cluster – Assistance Listing Numbers 84.063 and 84.268 In general, Cheyney University continues its trajectory of cross-functional and interrelated institutional improvements, particularly those impacting the National Student Loan Data System (NSLDS) that is reported through National Student Clearinghouse (NSC). Cited in the CLA Single Audit, nonetheless, are instances of inaccurate, late, or not reported enrollment and program level data to NSLDS. This response is intended to explain these reporting deficiencies and offer a corrective plan of action including timelines. Point Of Contact: • Dr. Denise Pearson, Provost – dpearson@cheyney.edu • Stephanie Stevens, Associate Registrar – sstevens@cheyney.edu • Jean Dixon, Associate Registrar – jedixon@cheyney.edu Explanations: This section represents Cheyney University’s effort to explain the causes for CLA Single Audit finding. Although the reporting deficiencies span multiple years, it is instructive to note that they are attributed to various and differing circumstances. While Cheyney University was on HCM2, the delay in Claims processing impacted the reporting in Common Origination and Disbursement (COD) and the reporting to NSLDS. The delays in approved claims caused an impact on NSLDS postings for enrollment reporting. This required Cheyney University administration to transfer from NSC to manual enrollment entry into NSLDS. The idea was to manually enter students’ records in NSLDS so that students’ enrollment could be reported more quickly. This is referenced in Single Audit Report, June 30, 2022; page 132. Cheyney is acutely focused on working toward compliance with NSLDS reporting requirements. Through this lens, it was discovered that during the 2024-2025 conversion to the Ellucian Banner system certain decisions were made regarding the conversion of student academic histories. During the research of errors and warning records received from the NSC upload, it was determined that program level information was not properly ported over to the new system. Cheyney University is pursuing a corrective course of action to improve this data to ensure accuracy in reporting. In May 2025, Cheyney University and NSC amended its agreement resulting in a shift in reporting student enrollment and program level data back to NSC from NSLDS that resulted in an additional delay in reporting. Due to these circumstances, the university dedicated significant resources to building capacity and capability in the Office of the Registrar, the functional area responsible for NSLDS reporting. These resources are being deployed in a variety of ways as noted in the Corrective Action Plan below. Corrective Action Plan Overview: 1. Hired a season University Registrar with superior, proven, leadership and technical skills. Emphasis has been placed on performance metrics that align with operational goals and objectives. STATUS: Anticipated March 2026. 2. Targeted professional development for Office of the Registrar and other staff including Banner training, NSC/NSLDS Reporting, and other dependencies. STATUS: Ongoing 3. Establishment of a dedicated compliance unit to support the university’s policies, standards, and procedures ecosystem. STATUS: Completed December 2025. 4. Hired a dedicated Chief Information and Technology Officer (as opposed to the use of third-party vendors). STATUS: Completed, March 2026. 5. Prioritized strengthening communication and collaboration with other enrollment management areas to establish cross-functional responsibilities and timelines (e.g., financial aid, admissions, and bursar offices). STATUS: Ongoing. Key Performance Indicators: During the Spring and Fall 2026 semesters: 1. The University Registrar will show outcomes-driven leadership practices that foster improved departmental performance, including audit citations. 2. Registrar and adjacent staff will demonstrate comprehensive capability and capacity in all areas related to NSC and NSLDS operations and reporting on a timely schedule. An organizational calendar is being developed to ensure this goal is met. 3. Utilizing the NSLDS instructional guide, train the Registrar and adjacent staff to improve the knowledge of the step-by-step process procedures for enrollment reporting, error correction, warning management, and internal audit review of NSLDS files. 4. Develop NSC instructional guide on reporting, error and warning management, and submission of monthly reporting data. 5. The Director of Policy and Compliance will collaborate with the Office of the Provost and Registrar Office staff to create and maintain a policy, procedures, and standards environment that supports operational excellence and efficiency (including more timely and accurate reporting). 6. The Chief Information and Technology Officer will conduct a comprehensive assessment of technology needs in the Office of the Registrar, including outcomes driven recommendations. 7. The Provost will establish Office of the Registrar protocols for collaboration with the Office of Communications to reinforce clarity, consistency, and transparency in all related matters. 8. The University Registrar will demonstrate that all staff have the requisite knowledge and skills to effectively mitigate future reporting deficiencies. Cheyney University acknowledges and affirms that this corrective action will be implemented, assessed, and become a standard operating procedure.
Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to findin...
Recommendation: The University should review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Increased frequency of NSC Submissions. Completing the error files returned to NSC quickly within the first 1-4 days of receipt after sending the files back. • We met with another PASSHE school on 4/22/25 and they helped us to strategize ensuring we meet the 60-day window for withdrawals by individually updating the withdrawal information in NSC on a weekly basis using our withdrawal report to identify each student withdrawal between our regular submissions. (Because we met with them so late in the audit cycle, we were not able to correct course for FY25 in time.) • We have adjusted our degree verification timeline, ensuring that the large bulk of our degree verification submission to NSC is completed within 2 weeks of the end of the graduating semester, ensuring that the bulk of our graduating students are moved from NSC to NSLDS sooner. • We updated our change of major policy to ensure that students are not changing majors after the end of the drop/add period. Prohibiting mid-semester major changes for the current semester will greatly reduce the number of status change errors reflected in NSC. This cleaner approach ensures less risk of error or delay related to volume. This was formalized with KU Policy ACA-029, approved at Senate on 9/4/25. Name(s) of the contact person(s) responsible for corrective action: Ben Trout, Registrar Planned completion date for corrective action plan: June 30, 2026
The Authority’s Board of Commissioners and management will continue to rely on the use of their outside auditors to prepare the schedule of expenditures of federal awards that were presented in accordance with generally accepted accounting principles. Management will assign a person within the Autho...
The Authority’s Board of Commissioners and management will continue to rely on the use of their outside auditors to prepare the schedule of expenditures of federal awards that were presented in accordance with generally accepted accounting principles. Management will assign a person within the Authority with the skills, knowledge and expertise to review and approve the schedule of expenditures of federal awards.
COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – ...
COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Ronaldo Ortiz Velázquez, Mayor Contact Person: Mrs. Eunice Díaz, Finance and Budget Director Phone: (787)738-3211 Original Finding Number: 2025-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: During the testing of reports, the Quarterly Progress Reports of five (5) projects, corresponding to two (2) quarters of fiscal year 2024-2025, were evaluated. It was found that in two (2) projects, the quarterly reports did not match the accounting records or the project documentation. Therefore, for the purposes of this audit, the municipal accounting controls and procedures did not ensure that the reported information was accurate, up-to-date, and fully reconciled with the financial records. In light of the above, the reports will be reconciled with the accounting records, and the discrepancies found will be identified, documented, and adjusted in the system where the error originated, as appropriate. Furthermore, from this point forward, once the Quarterly Reports (QPR) are issued, a copy must be sent to the Program Accountant, the Finance Director, and myself for validation and reconciliation prior to official filing, thus preventing situations like this to occur. This process will form part of the internal control required to ensure that the reported information is accurate, current, complete, and consistent with the accounting records, in accordance with applicable federal requirements. Implementation Date: From March 2026. Full implementation is expected in fiscal year 2026-2027. Responsible Person: Mrs. Natasha Vázquez Federal Programs Director
The College will be looking at making some business process changes to review files submitted to NSC (National Student Clearing House) and NSLDS (National Student Loan Data Service) monthly and perform monthly data reconciliation between responsible offices to ensure students are accurately reported...
The College will be looking at making some business process changes to review files submitted to NSC (National Student Clearing House) and NSLDS (National Student Loan Data Service) monthly and perform monthly data reconciliation between responsible offices to ensure students are accurately reported to ED/NSLDS. This new implementation will allow the College/Office to better verify each student’s enrollment status and visibility of reporting issues in the future. Timeline for Implementation of Corrective Action Plan: The procedure was implemented starting with the Spring 2026 semester and has continued since. Contact Person: Alex Jean-Jacques, Director of Financial Aid Operations
Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement wit...
Student Financial Assistance Cluster – Assistance Listing No. 84.033, 84.268, 84.063 & 84.007 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for 2024-004 Finding’s Recurrence: Related to case identified where a corrected Last Date of Attendance (Effective Date in Banner System on SFAWDRL input by the Financial Aid Office for a fully online student during the Unofficial Withdrawal [post term] Return of Title IV processing) was not carried over to Status Date in Banner maintained by the Registrar’s Office and to NSC/NSLDS so that all are reporting the accurate Last Date of Attendance, the University found that corrected dates during the semester aligned and were being reported to NSC/NSLDS in a timely manner, but that corrected dates after end of term were not being transmitted to NSC and NSLDS. Related to case identified of not reporting Graduated status to NSLDS in a timely manner: Typically, it takes approximately 2–3 weeks after commencement to clear degree audits and begin awarding degrees, as commencement occurs before final grades are released. The Graduate-only upload to NSC was completed on May 21, 2025.However, due to limitations with the National Student Clearinghouse (NSC) system, which does not accept multiple awards being posted simultaneously, we received an error report affecting approximately 60% of our graduates. Records included in this report must be corrected manually, which is a time-consuming process. We actively work to correct these records as quickly as possible within our current human resource limitations. The corrected error file related to the 2025-002 finding was uploaded to NSC on July 11, 2025, and sent to NSLDS on 7/12/2025. Action taken in response to finding: The University reviewed its procedures and implemented steps in our Unofficial Withdrawal [post term] Return of Title IV business process to include an email communication plan between the Financial Aid staff and the Office of the Registrar along with documentation sharing and added review steps to ensure the post-term corrected Last Date of Attendance is updated in all affected institutional and federal systems in a timely manner. The Office of the Registrar will correct errors returned from NSC within four weeks of receiving the file. To ensure this task is completed in a timely manner, we will allocate additional human resources as needed. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar, and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 08/06/2025
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with...
Student Financial Assistance Cluster – Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reviewed its procedures and reporting processes and added calendar reminders to run queries around our census day each term (since the case identified in the audit was due to a timing issue of a student’s aid period revision and when our automated Exit counseling processes are turned on) to find students who were missed by our automated processes for the adding of EXIT tracking requirement and ensuring timely notifications to the students. Name(s) of the contact person(s) responsible for corrective action James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Completion date for corrective action plan: 8/12/2025
The Organization is currently updating its Accounting Policies and Procedures. The revised policies will include a provision requiring that, if federal awards subject to Uniform Guidance (2 CFR Part 200) are received, all required federal financial reports will be independently reviewed and approved...
The Organization is currently updating its Accounting Policies and Procedures. The revised policies will include a provision requiring that, if federal awards subject to Uniform Guidance (2 CFR Part 200) are received, all required federal financial reports will be independently reviewed and approved prior to submission. The Board Treasurer will perform the review, or the Finance Committee Chair if the Treasurer is unavailable. Documentation of the review will be retained with the related reports.
Management is formalizing written enrollment reporting procedures to ensure timely and accurate reporting to NSLDS. Until implementation of a new student information system, enrollment reporting will continue to be performed manually, with monthly supervisory review and documentation of submissions....
Management is formalizing written enrollment reporting procedures to ensure timely and accurate reporting to NSLDS. Until implementation of a new student information system, enrollment reporting will continue to be performed manually, with monthly supervisory review and documentation of submissions. Automation of enrollment reporting is expected upon implementation of the new SIS.
Management has implemented formal monthly reconciliation procedures between the Financial Aid Office, Registrar, and Accounting Department to ensure the accuracy of the FISAP data. Reconciliations include review of enrollment status, aid disbursements, and supporting documentation, with documented s...
Management has implemented formal monthly reconciliation procedures between the Financial Aid Office, Registrar, and Accounting Department to ensure the accuracy of the FISAP data. Reconciliations include review of enrollment status, aid disbursements, and supporting documentation, with documented supervisory review and retention of reconciliation evidence.
Finding 2025-004 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: The Registrar prepares the program calendars with input from the programs on an annual basis. MSM has a diversity of programs with different start and end dates. We understand that this n...
Finding 2025-004 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: The Registrar prepares the program calendars with input from the programs on an annual basis. MSM has a diversity of programs with different start and end dates. We understand that this needs to be accurately reflected in our calendars and in the Banner system or other enrollment platform. Academic calendars will be reviewed by the Registrar and program staff on an annual basis. Any changes to the academic calendars will need to be communicated to all members of the team. Updated calendars will be posted annually on the website and in the student handbook. After the Registrar’s Office confirms the academic start date and academic end date, Student Fiscal Affairs will continue to input this information in our Student Information System Banner to allow accuracy in our student records sent to the Department of Education Common Origination and Disbursement. If there is a change in the academic start dates and/or academic end dates, the Registrar’s Office will notify Student Fiscal Affairs, Admissions, and Student Accounts to allow for updates within the institution. Anticipated Completion Date: March 1, 2026
Finding 2025-001 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: Due in part to frequent turnover in the Registrar's Office, there have been reporting errors in Clearinghouse which have been reflected in NSLDS. In addition to changes in personnel, the ...
Finding 2025-001 Name of Responsible Individual: Cinnamon Bradley, Assoc Dean Student Affairs Corrective Action: Due in part to frequent turnover in the Registrar's Office, there have been reporting errors in Clearinghouse which have been reflected in NSLDS. In addition to changes in personnel, the Office of the Dean will provide joint oversight with the Office of Student Affairs on matters impacting regulatory requirements. Specifically, there will be a monthly review of the NSLDS database on the second Monday of each month with a regular tracking system. The Registrar, Associate Dean of Students and Dean’s Office representative will provide quarterly “audits” to the Dean on accuracy of data and reporting compliance. Annual NSLDS training, appropriate to the role, will be provided for all team members in the Registrar's Office and others as appropriate. Anticipated Completion Date: March 31, 2026
2025-003 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board will design and implemen...
2025-003 Reporting U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board design and implement controls to ensure that all required reporting is submitted accurately and in a timely fashion. Action Taken: The Board will design and implement enhanced controls to ensure compliance with all reporting requirements by evaluating the existing reporting procedures and work to strengthen controls around preparation, review, and submission. These measures will help ensure that all reports are prepared accurately, reviewed appropriately, and submitted in a timely manner. We will proceed in this manner by training personnel in preparation and review. We will create a checklist so the breakdown in this report can be verified as correct and complete. Reports will not be submitted until these procedures have been completed.
The records maintained by the accounting department, including the general ledger, will be used to prepare future reports.
The records maintained by the accounting department, including the general ledger, will be used to prepare future reports.
Finding 2025–002: Material Journal Entries Condition: During our current year-end audit fieldwork, our testing resulted in material journal entries to be posted to properly state the City’s financial statements. Plan: The City Comptroller, along with staff, will review year-end adjustments as part o...
Finding 2025–002: Material Journal Entries Condition: During our current year-end audit fieldwork, our testing resulted in material journal entries to be posted to properly state the City’s financial statements. Plan: The City Comptroller, along with staff, will review year-end adjustments as part of the audit preparation process and work to reduce the number of entries proposed by the auditors and prepare fully adjusted financial statements prior to audit fieldwork. Anticipated Date of Completion: Fiscal Year Ending April 30, 2026 Name of Contact Person: Sheri Ray, Comptroller Management Response: Management acknowledges this finding and will work to correct it by the anticipated date of completion outlined above.
Finding 2025–001: Material Restatement to Fund Balance, Net Position, and Capital Assets Condition: During audit fieldwork, our testing resulted in a material restatement of Fund Balance, Net Position, and Capital Assets. Plan: The City will implement internal controls to properly record and adjust ...
Finding 2025–001: Material Restatement to Fund Balance, Net Position, and Capital Assets Condition: During audit fieldwork, our testing resulted in a material restatement of Fund Balance, Net Position, and Capital Assets. Plan: The City will implement internal controls to properly record and adjust necessary capital asset balances on a timely basis prior to audit fieldwork. Additionally, the City Comptroller will also provide monthly reviews of the financial statements. Anticipated Date of Completion: Fiscal Year Ending April 30, 2026 Name of Contact Person: Sheri Ray, Comptroller Management Response: Management acknowledges this finding and will work to correct it by the anticipated date of completion outlined above.
Finding 2025–003: Reporting Compliance Federal Agency: U.S. Department of Transportation Passthrough Entity: Illinois Department of Transportation Assistance Listing Number and Federal Program: 20.106 – Airport Improvement Program Condition: During our compliance procedures, we noted that the City d...
Finding 2025–003: Reporting Compliance Federal Agency: U.S. Department of Transportation Passthrough Entity: Illinois Department of Transportation Assistance Listing Number and Federal Program: 20.106 – Airport Improvement Program Condition: During our compliance procedures, we noted that the City did not complete, and submit in the proper time period, the necessary annual reports to the granting agency outlined in the Compliance Requirements shown in Uniform Guidance (2 CFR Part 200) for the Airport Improvement Program. Plan: The City Comptroller will meet with the Airport Director regularly to discuss the necessary reports required to be submitted to stay in compliance with the federal funding agency’s grant requirements. Prior to submission, the City Comptroller will review the reports with the Airport Director and then the necessary reports should be submitted on time and contain all the necessary information as outlined in the granting agency’s compliance requirements. Anticipated Date of Completion: Fiscal Year Ending April 30, 2026 Name of Contact Person: Sheri Ray, Comptroller Management Response: Management acknowledges this finding and will work to correct it by the anticipated date of completion outlined above.
Management will review grant reporting procedures and evaluate potential process refinements related to the calculation and inclusion of indirect costs with reimbursement requests, consistent with the approved indirect cost rate where applicable. The previous approach reflected a conservative decisi...
Management will review grant reporting procedures and evaluate potential process refinements related to the calculation and inclusion of indirect costs with reimbursement requests, consistent with the approved indirect cost rate where applicable. The previous approach reflected a conservative decision with respect to indirect cost recovery.
Management will review current grant tracking and reimbursement procedures and pursue improvements, as appropriate, to strengthen coordination across grant programs. Opportunities to enhance review processes prior to submission will also be considered to help minimize duplicate charges and support c...
Management will review current grant tracking and reimbursement procedures and pursue improvements, as appropriate, to strengthen coordination across grant programs. Opportunities to enhance review processes prior to submission will also be considered to help minimize duplicate charges and support compliance with federal requirements.
Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program including implementation of formal policies, reconciliation procedures, and enhanced oversight of interfund activi...
Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program including implementation of formal policies, reconciliation procedures, and enhanced oversight of interfund activity to ensure that established internal control policies are being followed on a timely basis. Steve Arlinghaus, Executive Director, is responsible for implementing this corrective action by June 30, 2026.
Finding: #2025-002- Time and Effort Reporting Assistance Listing/Program Title: #84.027 A/IDEA Flow Through and #84.173A/Preschool Entitlement (Special Education Cluster) Federal Agency/Pass-Through Entity: U.S Department of Education/Wisconsin Department of lnstruction Award Numbers/Year: 2025-1333...
Finding: #2025-002- Time and Effort Reporting Assistance Listing/Program Title: #84.027 A/IDEA Flow Through and #84.173A/Preschool Entitlement (Special Education Cluster) Federal Agency/Pass-Through Entity: U.S Department of Education/Wisconsin Department of lnstruction Award Numbers/Year: 2025-133332-DPI-FLOW-341 and 2025-133332-DPI-PRESCH-347/2024-2025 Criteria: In accordance with the federal Uniform Guidance, charges to federal awards for salaries and benefits must be based on records that accurately reflect the work performed. Such records must be supported by time and effort documentation. Condition: During the auditors' testing of payroll charges, it was noted that the District did not maintain adequate time and effmi documentation to support the allocation of salaries and benefits to the Special Education Cluster. Specifically, one employee's time was coded to the Special Education Cluster at a fixed 10% allocation. Cause: The District did not have adequate internal controls to ensure required time and effort documentation was consistently obtained and maintained for all employees whose salaries and benefits were charged to the Special Education Cluster. Staff turnover and lack of training contributed to inconsistent application of federal requirements. Effect: Because required time and effort documentation was not properly maintained, salaries and benefits charged to the Special Education Cluster may not accurately reflect actual time spent working on the program. As a result, these costs are unallowable under the Uniform Guidance. Questioned Costs: The absence of proper documentation results in questioned costs of $7,037, representing the salary and benefit amounts charged to the program for the one employee without adequate support. Recommendation: The auditor recommends that the District strengthen internal controls over time and effort reporting to ensure all employees funded in whole or in part by federal programs complete required documentation in accordance with Uniform Guidance. Additionally, a monitoring process should be implemented to ensure time distribution report is are completed accurately and retained in accordance with record-keeping requirements. Response: Management concurs with the finding and will implement internal control improvements to ensure full compliance with federal time and effort documentation requirements.
Corrective Action Plan - Federal Award Finding Finding 2025-001 Federal Agency Name: US DOT, Federal Railroad Administration Assistance Listing: 20.325 Program Name: Consolidated Rail Infrastructure and Safety Improvements (CRISI) Initial Year Finding Occurred: Fiscal Year 2025 Reporting Finding Sum...
Corrective Action Plan - Federal Award Finding Finding 2025-001 Federal Agency Name: US DOT, Federal Railroad Administration Assistance Listing: 20.325 Program Name: Consolidated Rail Infrastructure and Safety Improvements (CRISI) Initial Year Finding Occurred: Fiscal Year 2025 Reporting Finding Summary: The auditor identified an instance in which one quarterly SF-425 (report) did not reflect cumulative federal cash receipts and disbursements as required by the reporting instructions. Instead, the report reflected only the current quarter's ended federal cash activity. No additional reporting errors were identified by the audit, and the other reporting lines were prepared correctly. Auditor’s Recommendation: The auditor recommends that management continue to strengthen review procedures over SF-425 preparation, including documented review of cumulative cash reporting and verification of all report attributes, particularly during periods when backup personnel are responsible for report preparation. Management’s Response: Management concurs that an error occurred on one SF-425 report for a single reporting period. The error occurred during a sta􀆯ing transition and involved a field that FRA does not require, and that had not historically been populated. Additionally, FRA and FTA use the same SF-425 form but apply di􀆯erent reporting conventions; FTA requires the field to be reported quarterly rather than cumulatively, which contributed to the confusion. As noted in the audit finding, this was a reporting error only. There were no questioned costs, no billing inaccuracies, and no impact on the underlying financial activity. Corrective Action: Management has implemented the following actions to prevent recurrence: • Updated internal procedures to clearly distinguish FRA and FTA reporting requirements. • Implemented a two-step review process in which one sta􀆯 member prepares all federal financial reports and a second sta􀆯 member performs an independent review prior to submission. • Expanded procedure on reporting when primary sta􀆯 are unavailable, including cross training and adding backup for both reporting and review. These actions strengthen internal controls, ensure consistency across federal reporting, and reduce the risk of future reporting discrepancies. Responsible Individual: Heather McKillop, Chief Financial O􀆯icer Anticipated Completion Date: March 2026
Management will prepare the schedule of expenditures of federal awards as part of the year end closing process to determine our audit requirements under the Uniform Guidance and provide the schedule to the audit firm during the financial audit process.
Management will prepare the schedule of expenditures of federal awards as part of the year end closing process to determine our audit requirements under the Uniform Guidance and provide the schedule to the audit firm during the financial audit process.
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