Corrective Action Plans

Finding 539081 (2024-001)

Material Weakness 2024

University of Massachusetts Global-9 Month Audit

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding#2024-001: ...

Finding#2024-001: 40 files were sampled, and 18 files were found to have late reporting. We agree with the findings and have put forward an action plan to ensure this is not a repeat finding in the future. 17 out of 18 students that were part of the findings were reported within the 60 days, however, the program and campus level were not matching in NSLDS. Per the NSLDS Enrollment Reporting Guide, both the campus level enrollment reporting and program-level enrollment reporting should be updated every 60 days. To ensure both program and campus-level enrollments are updated within 60 days, our Registrar will be working closely with the National Student Clearinghouse. We are reviewing each report generated by our system to ensure that the main data elements are found in the report which include: - Student current SSN - OPEID - CIP Code - CIP Year - Credential level - Published Program Length Measurement - Published Program Length - Weeks in Title IV Academic Year - Program Begin Date - Program and Campus Enrollment Status - Special Program Indicator - Program and Campus Enrollment Effective Date - Certification Date In addition, we are carefully reviewing the reports and changing the timing of reporting. One of the 18 students that was part of the findings withdrew and was not reported timely. The university will monitor closely with NSC the timing of files and reporting. Finding #2024-001 Action: Implementation of new control: Registrar to review system generated reports to match NSLDS reporting guides and monitor closely the timing of when files are processed and reported to NSLDS. Name of contact person responsible for corrective action plan: Marilyn Payan, University Registrar Anticipated Completion Date: Currently being implemented, to be completed before 12/31/2024.

View Audit 349782

Finding 539080 (2024-002)

Significant Deficiency 2024

Army West Point Athletic Association, Inc.

NY

Questioned Costs Reporting § 200.328

Audit Finding: Pursuant to 2 CFR 200.327 and CFR 200.328 Report Requirements, Army West Point Athletic Association Inc. (“AWPAA”) did not submit its interim performance reports within 30 days after the completion of each reporting period. Root Cause Analysis: During FY2024, AWPAA did not submit it...

Audit Finding: Pursuant to 2 CFR 200.327 and CFR 200.328 Report Requirements, Army West Point Athletic Association Inc. (“AWPAA”) did not submit its interim performance reports within 30 days after the completion of each reporting period. Root Cause Analysis: During FY2024, AWPAA did not submit its quarterly interim performance reports in accordance with the CA requirements. Instead, AWPAA submitted the FY2024 quarterly reports concurrently in October 2024. This was an oversight by the AWPAA & Government Program Management Teams. Corrective Action Plan: To review the interim performance reporting requirements as outline in Section 10B of the Cooperative Agreement and coordinate the timely monitoring and submission of these quarterly reports by the AWPAA Program Management Team. Estimated Completion Date: October 30, 2024 and note: Interim Performance Report for the period ended September 30, 2024 was submitted October 28, 2024 (due by October 30, 2024). Interim Performance Report for the period ended December 31, 2024 was submitted January 29, 2025 (due by January 30, 2025).

View Audit 349781

Finding 539074 (2024-001)

Significant Deficiency 2024

Northern Essex Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Corrective Action Plan: In the Fall of 2023, the Registrar of 25 years retired, and the Assistant Registrar was...

Finding number: 2024-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.007, 84.063, 84.268 Award year: 2024 Corrective Action Plan: In the Fall of 2023, the Registrar of 25 years retired, and the Assistant Registrar was promoted to replace her. During the transition, the new Registrar got behind in submitting Enrollment Reports for Spring 2024. The result of the first report being behind schedule caused a backlog of Enrollment and Error reports which resulted in a delay for the enrollment reports to be sent to NSLDS. The Registrar has made it a priority to submit enrollment reports and error reports in a timely manner (within 24-48 hours) so that they can be submitted to NSLDS within the 60-day timeframe. Timeline for Implementation of Corrective Action Plan: Corrective action plan began immediately when the next semester began. The action plan appears to be successful as there was no backlog of Enrollment/Error reports for Summer 2024, Fall 2024, and into Spring 2025 semester. Contact Person: Registrar – Shawna Lind

View Audit 349777

Finding 539073 (2024-012)

Significant Deficiency 2024

City of Boston

MA

Reporting Internal Control / Segregation of Duties § 200.303

Boston Fire Department has incorporated and implemented proper control procedures around all grant related matter; including but not limited to financial reporting and oversight. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Moni...

Boston Fire Department has incorporated and implemented proper control procedures around all grant related matter; including but not limited to financial reporting and oversight. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776

Finding 539065 (2024-007)

Significant Deficiency 2024

City of Boston

MA

Matching / Level of Effort / Earmarking Questioned Costs HUD Housing Programs § 200.303

Boston Public Schools has updated training for school leaders to review school leader certification of withdrawals. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776

Finding 539063 (2024-005)

Significant Deficiency 2024

City of Boston

MA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

The City will implement procedures so that there is documentation of review, approval and submission of FFATA reports. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776

Finding 539061 (2024-003)

Significant Deficiency 2024

City of Boston

MA

Questioned Costs School Nutrition Programs Cash Management § 200.303

Boston Public Schools Food and Nutrition Services has begun implementing advanced policies including additional segregation of duties and additional documentation to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2025 Responsible Co...

Boston Public Schools Food and Nutrition Services has begun implementing advanced policies including additional segregation of duties and additional documentation to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2025 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 349776 Questioned Costs: $1

Finding 539059 (2024-004)

Significant Deficiency 2024

Matchbook Learning Schools of Indiana, Inc.

IN

Reporting Significant Deficiency Internal Control / Segregation of Duties

Response to Finding 2024-004 – Maintenance of Effort 1. Improving Accuracy of the Form 9 Report (Completion: Within 6 months) o Implementing monthly reconciliations to ensure Form 9 expenditures match financial records. o Assigning a dedicated financial officer to oversee and verify Form 9 complianc...

Response to Finding 2024-004 – Maintenance of Effort 1. Improving Accuracy of the Form 9 Report (Completion: Within 6 months) o Implementing monthly reconciliations to ensure Form 9 expenditures match financial records. o Assigning a dedicated financial officer to oversee and verify Form 9 compliance. 2. Strengthening Reporting and Internal Controls (Completion: Within 9 months) o Conducting regular audits of Form 9 data before submission to the Indiana Department of Education. o Developing a standardized reporting checklist to ensure compliance with state and federal MOE requirements.

View Audit 349775

Finding 539058 (2024-001)

None 2024

Kennebec Montessori School

ME

Reporting Matching / Level of Effort / Earmarking

Management will establish more oversight on the submission of data collection form.

View Audit 349774

Finding 539047 (2024-001)

Significant Deficiency 2024

Santa Clara University

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-001: Criteria Institutions must report disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the ins...

Purpose: To document Santa Clara University’s Corrective Action Plan relating to finding 2024-001 in its June 30, 2024 Single Audit Report. Finding #2024-001: Criteria Institutions must report disbursement data to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that disbursements are reported in a timely manner. Statement of Condition During testwork, KPMG selected 40 students that had Pell Grant or Direct Loan disbursements where the University was required to report student disbursement date to Common Origination and Disbursement (COD) system within 15 calendar days after the institution makes a disbursement or becomes award of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. KPMG identified 5 of the 40 students were not reported to COD in a timely manner. Corrective Action Planned The University agrees with this assessment and is implementing a new process to ensure Direct Loan and Pell Grant disbursements will now be reviewed after each disbursement (Monday, Wednesday, and Friday) and are reported within the Department of Education's requirements. Additionally, we will ensure that the COD Workday outbound and inbound integrations are monitored daily. Name of contact Person responsible for corrective action plan Sandra Hayes, Assistant Vice President for Enrollment Management Anticipated completion date The above measures have already been implemented.

View Audit 349756

Finding 539026 (2024-004)

Material Weakness 2024

Milan Community Schools

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328

FINDING 2024-004 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Ide...

FINDING 2024-004 Information on the federal program: Subject: COVID-19 – Education Stabilization Fund – Reporting Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. Context: The School Corporation was required to submit Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the following exceptions in data reporting submissions:  ESSER I Year 4, ESSER II Year 3, and ESSER III Year 3 expenditures for the period of July 1, 2021 through June 30, 2022 ($0, $360,404, and $12,974, respectively) did not agree to underlying expenditure records ($60,937, $477,914, and $0, respectively).  ESSER II Year 4 and ESSER III Year 4 expenditures for the period of July 1, 2022 through June 30, 2023 ($57,667 and $363,486, respectively) did not agree to underlying expenditure records ($361 and $400,473, respectively). Description of Corrective Action Plan: Management will implement control processes surrounding federal data reporting to ensure that expenditures reported to granting agencies are in agreement with underlying records maintained by the School. Responsible Party and Timeline for Completion: Gretchen Berger, Corp Treasurer - 6-1-2025

View Audit 349745

Finding 539012 (2024-003)

Significant Deficiency 2024

Marshall University Research Corporation

WV

Questioned Costs Reporting Significant Deficiency § 200.303

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Update policies and procedures ensuring performance and FFATA reports are accurately prepared and submitted in accordance with grant deadlines. Explanation of disagreement with audit finding: There is...

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Update policies and procedures ensuring performance and FFATA reports are accurately prepared and submitted in accordance with grant deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will create internal control policies and procedures to ensure performance and FFATA reports are accurately prepared and submitted in accordance with grant deadlines. Name(s) of the contact person(s) responsible for corrective action: Jennifer Wood and Joe Ciccarello Planned completion date for corrective action plan: June 30, 2025

View Audit 349740

Finding 539007 (2024-002)

Significant Deficiency 2024

Marshall University Research Corporation

WV

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.308 § 200.309 § 200.403

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with ...

Substance Abuse and Mental Health Services Projects - Assistance Listing No. 93.243 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name(s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

View Audit 349740

Finding 539002 (2024-001)

Significant Deficiency 2024

Marshall University Research Corporation

WV

Subrecipient Monitoring Reporting Questioned Costs § 200.308 § 200.309 § 200.403

Research and Development Cluster- Assistance Listing Nos. 93.323, 93.847 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit f...

Research and Development Cluster- Assistance Listing Nos. 93.323, 93.847 Recommendation: Perform a review policies and procedures regarding proper monitoring of period of performance related to grant end dates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: MURC will perform a review of policies and procedures to ensure recorded transactions are within the proper period of performance related to grant end dates. Name{s) of the contact person(s) responsible for corrective action: Jennifer Wood Planned completion date for corrective action plan: June 30, 2025

View Audit 349740 Questioned Costs: $1

Finding 538995 (2024-003)

Significant Deficiency 2024

Madison County, Nebraska

NE

Questioned Costs Subrecipient Monitoring Reporting

Corrective Action Planned: The County relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal and state awards include related note disclosures. The County reviews schedule of expenditures of federal awards and approves all adjustments. Proposed ...

Corrective Action Planned: The County relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal and state awards include related note disclosures. The County reviews schedule of expenditures of federal awards and approves all adjustments. Proposed Completion Date: Ongoing Responsible Party: Anne M. Pruss, County Clerk

View Audit 349703

Finding 538994 (2024-003)

Significant Deficiency 2024

Holyoke Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: To prevent conflicts between student work schedules and class schedules, the Financial Aid Office will verify, at the beginning of each term, that Federal Work-Study (“FWS”) student work schedules do not conflict with their academic schedules. As part of this verification pro...

Corrective Action Plan: To prevent conflicts between student work schedules and class schedules, the Financial Aid Office will verify, at the beginning of each term, that Federal Work-Study (“FWS”) student work schedules do not conflict with their academic schedules. As part of this verification process, department managers hiring FWS students will submit both the student's work schedule and class schedule to the Financial Aid Office. A report has been developed to compare FWS student work hours with their class schedules during each pay period. Any instances of students working during scheduled class time will be communicated to both the student and their supervisor for correction, if the hours were reported in error. If the hours are accurate, the department must provide documentation of a class schedule change, cancellation, or the fund and organization codes to be charged, crediting the FWS funds accordingly. Timeline for Implementation of Corrective Action Plan: This policy will be implemented immediately and applied retroactively to July 1, 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Curt Foster, Comptroller

View Audit 349701

Finding 538991 (2024-001)

Significant Deficiency 2024

Holyoke Community College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: Despite previous corrective actions addressing NSLDS reporting findings, an audit has revealed additional discrepancies in reporting between HCC and the National Student Clearinghouse (“NSC”). Our current database generates a file for submission to the NSC, intended to report...

Corrective Action Plan: Despite previous corrective actions addressing NSLDS reporting findings, an audit has revealed additional discrepancies in reporting between HCC and the National Student Clearinghouse (“NSC”). Our current database generates a file for submission to the NSC, intended to report all graduates. Upon review of the data transmission process, it has been determined that students enrolled in simultaneous degree programs require specific evaluation of their graduate status due to the NSC's unique parameters for these programs. Consequently, manual updates to NSLDS will be necessary for cases that fall outside the NSC's automated reporting guidelines. To address this systematically, a working group will be established to review and revise campus policies and procedures. This group will collaborate with the IT Enterprise Operations team to develop refined reporting mechanisms that accurately identify and address students in simultaneous degree programs, ensuring timely and accurate NSLDS reporting. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2024. Contact Person Todd Wonders, Associate Director of Financial Aid Allison Wrobel, Registrar Curt Foster, Comptroller

View Audit 349701

Finding 538989 (2024-002)

Significant Deficiency 2024

City of Osakis

MN

Reporting Significant Deficiency

Preparation of Financial Statements and Related Footnotes

View Audit 349672

Finding 538989 (2024-002)

Significant Deficiency 2024

City of Osakis

MN

Reporting Significant Deficiency

Recommendation: This control deficiency is not unusual in a small city. However, it is the responsibility of management and the Council to decide whether to accept the degree of risk associated with this condition based on the cost of correction and other considerations.

View Audit 349672

Finding 538989 (2024-002)

Significant Deficiency 2024

City of Osakis

MN

Reporting Significant Deficiency

Management’s Response and Actions Planned: The City’s management is aware of this significant deficiency. Management reviews and approves the draft annual audited financial statements and distributes them to the users. For entities of this size, it generally is not practical to obtain the internal e...

Management’s Response and Actions Planned: The City’s management is aware of this significant deficiency. Management reviews and approves the draft annual audited financial statements and distributes them to the users. For entities of this size, it generally is not practical to obtain the internal expertise needed to handle all aspects of the external financial reporting. Management recognizes this and feels it is effectively handling its reporting responsibilities with the procedures described above.

View Audit 349672

Finding 538987 (2024-002)

Significant Deficiency 2024

County of Bristol, Masaachusetts

MA

Subrecipient Monitoring Reporting

The County is in the process of revising our internal control policies which will formally document our overall management responsibilities including duties, extent and adequacy of monitoring, timeliness, evaluation and acceptance of results. This will be in place for FY26.

View Audit 349662

Finding 538978 (2024-003)

Significant Deficiency 2024

Morehouse School of Medicine, Inc., Subsidiary and Affiliate

GA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Questioned Costs § 200.430

Finding 2024-003 Name of Responsible Individual: Tamara Hill, AVP Research Operations and Finance Corrective Action: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting ...

Finding 2024-003 Name of Responsible Individual: Tamara Hill, AVP Research Operations and Finance Corrective Action: We concur. We are identifying personnel that will be allocated to federal awards to ensure all effort reports are reviewed and certified timely. During the next effort reporting cycle, the school will transition to a new automated system, Cayuse effort reporting. This will give the Office of Grants & Contracts Faculty and Staff increased visibility into the personnel allocated to federal awards in a more efficient manner. We will complete the corrective action no later than June 30, 2025. Anticipated Completion Date: June 30, 2025

View Audit 349645

Finding 538976 (2024-002)

Significant Deficiency 2024

Morehouse School of Medicine, Inc., Subsidiary and Affiliate

GA

Reporting § 200.328 § 200.329

Finding 2024-002 Name of Responsible Individual: Tamara Hill, AVP Research Operations and Finance Corrective Action: We concur. We will review our processes and ensure timely and accurate completion of reporting. We will complete the corrective action no later than June 30, 2025. Anticipated Co...

Finding 2024-002 Name of Responsible Individual: Tamara Hill, AVP Research Operations and Finance Corrective Action: We concur. We will review our processes and ensure timely and accurate completion of reporting. We will complete the corrective action no later than June 30, 2025. Anticipated Completion Date: June 30, 2025

View Audit 349645

Finding 538975 (2024-001)

Significant Deficiency 2024

Morehouse School of Medicine, Inc., Subsidiary and Affiliate

GA

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

Finding 2024-001 Name of Responsible Individual: Cinnamon Bradley, Associate Dean of Student Affairs Corrective Action: We concur. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. We will also imple...

Finding 2024-001 Name of Responsible Individual: Cinnamon Bradley, Associate Dean of Student Affairs Corrective Action: We concur. We will review our procedures to ensure proper recording of these changes by NSLDS based on our submission to the National Student Clearinghouse. We will also implement an automated monitoring notification system that will alert us within the established timeframe of status changes to ensure accuracy in both third-party systems. Change in our submission process to the National Student Clearinghouse from 30 days to occur weekly to ensure timely reporting to NSLDS. All student records contained in the NSLDS for the Academic Term will be reviewed every month and the student roster will be reviewed weekly for accuracy in both third-party systems. We will complete the corrective action no later than March 31, 2025. Anticipated Completion Date: March 31, 2025

View Audit 349645

Finding 538861 (2024-003)

Material Weakness 2024

North Judson -- San Pierre School Corporation

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: An internal controls procedure will be put into place that ensures annual data reports are both revi...

Contact Person Responsible for Corrective Action: Dalton C. Tunis Contact Phone Number: 574-896-2155 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: An internal controls procedure will be put into place that ensures annual data reports are both reviewed and signed off on before submitting. The procedure will be that the Business Manager prepares the report and then reviews the report with the Superintendent. Once the Superintendent approves of the report he or she will sign of on the report and the report can be submitted. Documentation will be recorded to ensure the School Corporation stays in compliance with the requirements related to grant agreements and reporting requirements. Anticipated Completion Date: June 30, 2025

View Audit 349621

Corrective Action Plans

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