Corrective Action Plans

Finding 526022 (2024-001)

Significant Deficiency 2024

MI

Subrecipient Monitoring Questioned Costs Reporting

Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountabilit...

Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. The Commission did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. As a result, the Commission did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the Commission review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: Management concurs with the finding. The Commission will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement. Responsible Person: Joseph Bertram, Financial Operations Manager. Anticipated Completion Date: June 30, 2025.

View Audit 345168

Finding 525976 (2024-002)

None 2024

Converse University

SC

Questioned Costs Student Financial Aid Subrecipient Monitoring

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, ...

Compliance Requirement Finding: Special Test and Provisions – Enrollment Reporting The University had not reported changes of the sampled graduated or withdrawn students to the National Student Loan Data System (“NSLDS”) as required under the Uniform Grant Guidance for the year ended June 30, 2024, accurately or timely. Student Financial Aid Cluster, Assistance Listing # 84.007, 84.033, 84.038, 84.063, 84.268 Corrective Action Plan The finding was due to a lack of a process to correctly backdate administrative withdrawals when a student receives a "W" grade after the withdrawal deadline. This inconsistency led to inaccurate reporting to the National Student Loan Data System (NSLDS) and the academic file. To address this, management has collaborated with the Offices of Campus Technology, Student Financial Services, and the Registrar and has developed and implemented better procedures for handling administrative withdrawals. These procedures will ensure: • Consistent reporting of withdrawal dates to NSLDS. • Ensuring that withdrawal dates are recorded uniformly in both the Registrar’s office and Student Financial Services. • Accurate assignment of "W" grades according to the academic calendar. These new procedures were implemented in the beginning of 2024. The Registrar’s office will continue to submit regular enrollment reports to NSLDS, promptly reporting any changes to student enrollment as required. The Office of the Registrar will be responsible for implementing the corrective action plan, under the supervision of the University Registrar and Director of Institutional Research and Effectiveness. Shannon Bishop Shannon.bishop@converse.edu University Registrar

View Audit 345135

Finding 525913 (2024-001)

Material Weakness 2024

The House of Hope, Inc.

FL

Reporting

Criteria: Timely preparation of account reconciliations is essential to producing accurate and relevant financial reports. Condition: During the audit, a number of adjusting journal entries were proposed by both the audit team and management. These entries were to adjust errors or to reflect year-en...

Criteria: Timely preparation of account reconciliations is essential to producing accurate and relevant financial reports. Condition: During the audit, a number of adjusting journal entries were proposed by both the audit team and management. These entries were to adjust errors or to reflect year-end accruals. Cause: Existing closing procedures should be reviewed and updated to ensure that they are properly followed in producing timely reports and reducing year-end adjustments. Effect: The results were delays in producing reconciliations, account analyses and other financial reports needed by management and the auditors. Recommendation: We believe that the year-end closing could proceed more quickly by incorporating a closing schedule that indicates who will perform each procedure and when completion of each procedure is due and accomplished. The timing of specific procedures could be coordinated with the timing of management’s or the auditor’s need for information. All reconciliations should be prepared and reviewed by those informed of such matters to ensure accuracy. Management Response: We acknowledge that the finding identified in the 2023 audit has repeated in the 2024 audit, and we recognize the importance of fully addressing these concerns to ensure more accurate and efficient financial procedures moving forward. We have since successfully hired a qualified staff accountant who is now in place and working diligently to ensure compliance with all financial procedures for the fiscal year 2025. This key hire, along with the enhanced and fully implemented month-end checklist, will help us consistently meet the necessary financial reporting standards.

View Audit 345049

Finding 525887 (2024-002)

Significant Deficiency 2024

Kildahl Park Pointe Cooperative

MN

Questioned Costs Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperativ...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 345043

Finding 525868 (2024-001)

Significant Deficiency 2024

United Ways of Iowa

IA

Reporting Significant Deficiency Internal Control / Segregation of Duties

UWI management identified the late reporting error during the year and made alternative arrangements with the grantor to come into compliance prior to fiscal year end. To assure compliance with federal grants, procedures are in place for grant reporting oversignt.

View Audit 345031

Finding 525866 (2024-001)

Significant Deficiency 2024

Adlai E. Stevenson H.s. 125

IL

Reporting

Condition: The 2023 data collection form and audit package were not submitted timely. Plan: The Superintendent, along with staff, will review and evaluate the reporting requirements of all grants to ensure timely reporting requirements. Anticipated Date of Completion: June 30, 2025

View Audit 345024

Finding 525855 (2024-003)

Material Weakness 2024

Unified School District No. 321

KS

Reporting Subrecipient Monitoring Material Weakness § 200.502

2024-003 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Number: 10.553, 10.555 and 10.559; 84.42...

2024-003 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Child Nutrition Cluster; Education Stabilization Fund Assistance Listing Number: 10.553, 10.555 and 10.559; 84.425 Award Period: June 30, 2024 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to have the Board Clerk and the Board Treasurer complete the Schedule of Expenditures together and to ensure that the correct expenses are being reported. Contact Name – Kristy Dyche Expected Completion Date – 6/30/2025

View Audit 344992

Finding 525806 (2024-006)

Material Weakness 2024

Village of Green Island, New York

NY

Reporting

The Village will implement a process of how expenditures of Federal Awards are recorded and monitoring this process.

View Audit 344975

Finding 525784 (2024-002)

Significant Deficiency 2024

Bay Cove Human Services, Inc. & Affiliate

MA

Subrecipient Monitoring Reporting Significant Deficiency

Management agrees with the finding and is in the process of revising internal controls to address this issue.

View Audit 344938

Finding 525782 (2024-002)

Material Weakness 2024

Town of Merrimack

NH

Cash Management Internal Control / Segregation of Duties Material Weakness § 200.303

Audit Finding Reference: 2024-002 Management’s Response and Planned Corrective Action: We have developed a procedure of printing out all State of NH remittance advices. -Check bank receipts daily. -Print out the State of NH remittance advices. -Confirm Funds were received. -Book the receipt to U...

Audit Finding Reference: 2024-002 Management’s Response and Planned Corrective Action: We have developed a procedure of printing out all State of NH remittance advices. -Check bank receipts daily. -Print out the State of NH remittance advices. -Confirm Funds were received. -Book the receipt to Unifund. Name of Contact Person and Completion Date: Name 1: Paul Calabria Name 2: Xenia Simpson Anticipated Completion Date – February 25, 2025

View Audit 344936

Finding 525761 (2024-001)

Material Weakness 2024

South Vermillion Community School Corporation

IN

School Nutrition Programs Subrecipient Monitoring Cash Management § 200.202 § 200.211 § 200.301 § 200.303 § 200.328

FINDING 2024-001 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the reporting requirements. The reimbursement request reports were prepared and submitted by the Food Service Director without...

FINDING 2024-001 Finding Subject: Child Nutrition Cluster - Reporting Summary of Finding: There were no controls in place to ensure that the School Corporation complied with the reporting requirements. The reimbursement request reports were prepared and submitted by the Food Service Director without any oversight, review or approval process to ensure accuracy of the reports. There was no oversight to make sure that the number of meals served matched the report filed. The lack of internal controls was systemic throughout the audit period. Contact Person Responsible for Corrective Action: Amanda Myers Contact Phone Number and Email Address: 765-832-3551/amyers@svcs.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Amanda Myers, Food Services Director, will continue to receive the information for the monthly meals served from the cafeteria managers at each school. Once she enters the information, the HS cafeteria manager will review the numbers to ensure that the information was entered correctly. The reimbursement forms and information that was entered will be submitted to the finance department to ensure the reimbursement process is correctly receipted. Anticipated Completion Date: Immediate.

View Audit 344930

Finding 525756 (2024-001)

Significant Deficiency 2024

Morehouse Place Cooperative

MN

Questioned Costs Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperativ...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 344916

Finding 525707 (2024-016)

Material Weakness 2024

Woodland Park School District Number Re-2

CO

Subrecipient Monitoring Reporting Material Weakness

2024-016 Reporting for Education Stabilization Fund Federal program: ALN 84.425U&D Education Stabilization Fund Federal agency: U.S. Department of Education Pass-through entity: Colorado Department of Education Criteria: ESSER grantees must submit an annual performance report with dat...

2024-016 Reporting for Education Stabilization Fund Federal program: ALN 84.425U&D Education Stabilization Fund Federal agency: U.S. Department of Education Pass-through entity: Colorado Department of Education Criteria: ESSER grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. An LEA is required to submit certain annual financial reports to its SEA on an annual basis. Condition: The District did not timely file the annual financial report and the filed report did not agree to the general ledger. The District did not file its annual financial report for grant 4414 until February of 2025. The District has not filed its annual financial report for the ARP-Mentor grant. Management Response and Planned Corrective Actions Criteria: Grant accounting was performed by a part-time contractor who left at beginning of the fiscal year. The CFO absorbed those accounting tasks within the remaining finance team. Failure to file ESSER reporting timely was communicated by Superintendent to CFO when the CDE sent notice, but reporting was not completed before dismissal. Management will ensure controls are in place to confirm grant accounting and reporting are reviewed, completed, correct, and timely. Management will further ensure grant accounting expertise is again employed or contracted in the district. Responsibility for Corrective Action: Ken Witt, Superintendent Anticipated Completion Date: Summer of 2025

View Audit 344875

Finding 525689 (2024-001)

Significant Deficiency 2024

Middle Kentucky Community Action Partnership, Inc.

KY

Questioned Costs Subrecipient Monitoring Reporting

Management agrees with the finding and has committed to a corrective action plan. Middle Kentucky has the use of a scheduling calendar in which required dates of reports and other key events are now placed. Middle Kentucky CFO has added the dates of reports including the FSRS report and its due date...

Management agrees with the finding and has committed to a corrective action plan. Middle Kentucky has the use of a scheduling calendar in which required dates of reports and other key events are now placed. Middle Kentucky CFO has added the dates of reports including the FSRS report and its due date. From this calendar an alert can and will e sent to the CFO and a designated second person to alert them as to the upcoming required date that this and other reports are to be submitted. The calendar both electronic and in written form is now in use and no further instances of this occurrence should occur within the fiscal department in the future.

View Audit 344835

Finding 525687 (2024-001)

Significant Deficiency 2024

The Primary Care Coalition of Montgomery County, Maryland, Inc.

MD

Questioned Costs Subrecipient Monitoring Eligibility

Views of Responsible Officials: Management agrees with the finding and has already filed the required FFATA report. Completion Date: 11/22/2024

View Audit 344804

Finding 525682 (2024-004)

Material Weakness 2024

Flat Rock - Haw Creek School Corporation

IN

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

Context: The School Corporation was required to submit two 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 ESSER I, ESSER II, and ESSER III amounts reported for the reports cov...

Context: The School Corporation was required to submit two 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 ESSER I, ESSER II, and ESSER III amounts reported for the reports covering the FY22 time period ($3,000, $0 and $0, respectively) did not agree to the underlying expenditure records ($0, $207,168, and $104,885, respectively, for the period of July 1, 2021 through June 30, 2022). Additionally, we noted that the ESSER II, and ESSER III amounts reported for the reports covering the FY23 time period ($328,359 and $334,119, respectively) did not agree to the underlying expenditure records ($121,193 and $229,234, respectively, for the period of July 1, 2022 through June 30, 2023). Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Business Manager and Assistant will jointly review all expenditures or fedral grant awards with in the fiscal year that are to be reported to ensure accuracy of reporting. Anticipated Completion Date: July 2025

View Audit 344796

Finding 525679 (2024-003)

Significant Deficiency 2024

Flat Rock - Haw Creek School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

Context: For one sponsor claim reimbursement in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Contact P...

Context: For one sponsor claim reimbursement in a sample of four claims, the Food Service Director prepared the sponsor claim reimbursement summary without a secondary, documented review before the submission of the claim to ensure the accuracy of the sponsor claim reimbursement summary. Contact Person Responsible for Corrective Action: Melissa Dempsey Contact Phone Number: 812-546-2000 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: I have spoken to the Food Service Director to ensure that 2 individuals are signing off on all the claims. Anticipated Completion Date: 3/1/2025

View Audit 344796

Finding 525669 (2024-003)

Significant Deficiency 2024

Community College District of Gogebic County

MI

Questioned Costs Reporting Significant Deficiency

Auditor Description of Condition and Effect. During our review of the submitted quarterly reports, we noted there were errors in the amounts reported. As a result, the College's quarterly ADN-to-BSN reports were prepared incorrectly and were not corrected until the mistakes were identified by the au...

Auditor Description of Condition and Effect. During our review of the submitted quarterly reports, we noted there were errors in the amounts reported. As a result, the College's quarterly ADN-to-BSN reports were prepared incorrectly and were not corrected until the mistakes were identified by the auditors. Auditor Recommendation. We recommend that the College implement a reconciliation and review process over the preparation and reporting of the ADN-to-BSN quarterly reports to ensure proper and accurate reporting. Corrective Action. The College has performed the necessary steps to correct the error and will correct the amounts reported in the next quarterly report. Additionally, the reporting process will include a reconciliation of the expenses and an additional level of review. Responsible Person. Chad Lashua, Vice President of Business Services. Anticipated Completion Date. April 30, 2025.

View Audit 344780

Finding 525665 (2024-002)

Significant Deficiency 2024

Community College District of Gogebic County

MI

Student Financial Aid Questioned Costs Internal Control / Segregation of Duties

Auditor Description of Condition and Effect. During our review of the Fiscal Operations Report and Application to Participate (FISAP), we noted there were errors in the amounts reported. As a result, the College's FISAP was prepared incorrectly and had to be resubmitted to the Department of Federal ...

Auditor Description of Condition and Effect. During our review of the Fiscal Operations Report and Application to Participate (FISAP), we noted there were errors in the amounts reported. As a result, the College's FISAP was prepared incorrectly and had to be resubmitted to the Department of Federal Student Aid. Auditor Recommendation. We recommend that the College implement a secondary review process over the preparation and reporting of the FISAP to ensure proper and accurate reporting. Corrective Action. The College has performed the necessary steps to correct the error and will amend the reporting process to ensure that a second individual is reviewing the work performed. Responsible Person. Maryann DeCaire, Director of Financial Aid. Anticipated Completion Date. April 30, 2025.

View Audit 344780

Finding 525639 (2024-005)

Significant Deficiency 2024

Cottey College

MO

Questioned Costs Student Financial Aid Special Tests & Provisions

Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the...

Condition: The College did not timely and accurately complete refund calculations in the Spring. In review of the Spring 2024 calculations the scheduled end date did not consider finals week, resulting in the incorrect days in all Spring 2024 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV amounts returned for all withdrawn students were incorrectly calculated for 2 out of the population of 5 (40%) Spring withdrawal calculations as two students had attended over 60% of the semester for both the original and updated calculations and as such, no return was required. A sample of two Fall withdrawal calculations identified one error (50%) due to incorrect inputs for awards that were disbursed and those that could have been disbursed. We consider this finding to be a significant deficiency in relation to Special Tests and Provisions compliance requirement and is a repeat finding shown in Section IV of this report as prior year finding 2023-005. Statistical sampling was not used in making sample selections. Corrective Action Plan: This repeated finding was due to our previously delayed audits. We implemented the plan below on 09/10/2024 after the 2023-05 finding, however, the 2023-24 school year had already completed. This meant we were unable to make changes in the year as it had already concluded, and we implemented the corrective action plan for the 2024-25 school year. 2023-005 Corrective Action Plan: Corrective Action Plan: The Registrar’s Office will review the school calendar in Common Origination and Disbursement Web Site before the financial aid office begins processing R2T4’s for the school year. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) and Chayna Penney (Registrar) Implementation Date for Corrective Action Plan: 09/10/2024 Responsible Person for Correction Action Plan: Hannah Masters Implementation Date for Corrective Action Plan: 01/30/2025

View Audit 344753 Questioned Costs: $1

Finding 525621 (2024-001)

Material Weakness 2024

Young Women's Christian Association of Pueblo

CO

Reporting § 200.510

Management did not have an independent reviewer for the SEFA document preparation this year which resulted in an error being identified by the auditors. The error was mathematical in nature and could have been identified by a second reviewer. For future reporting, the SEFA will be reviewed by the Ex...

Management did not have an independent reviewer for the SEFA document preparation this year which resulted in an error being identified by the auditors. The error was mathematical in nature and could have been identified by a second reviewer. For future reporting, the SEFA will be reviewed by the Executive Director, Accountant, and Board Treasurer prior to being sent to the auditors and will be distributed in ‘draft’ form until completed.

View Audit 344729

Finding 525618 (2024-001)

None 2024

Town of Dudley, Massachusetts

MA

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

When the reporting portal opens in late March 2025 for Annual Reports due by April 30, 2025 (for the April 1, 2024-March 31, 2025 reporting period), the Town Accountant will enter a project under expenditure category 6.1 (Revenue Replacement) that will include the $3,519,030.12 that was obligated an...

When the reporting portal opens in late March 2025 for Annual Reports due by April 30, 2025 (for the April 1, 2024-March 31, 2025 reporting period), the Town Accountant will enter a project under expenditure category 6.1 (Revenue Replacement) that will include the $3,519,030.12 that was obligated and expended by Dudley for revenue replacement. On the overview section of the 2024 report the town will report the full $3,519,030.12 as obligated and expensed.

View Audit 344723

Finding 525614 (2024-005)

Significant Deficiency 2024

Bluefield University

VA

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Enrollment Reporting (Significant Deficiency). Condition: The University did not report student enrollment data to the National Student Clearinghouse within the minimum required timefr...

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Enrollment Reporting (Significant Deficiency). Condition: The University did not report student enrollment data to the National Student Clearinghouse within the minimum required timeframe. Criteria: Based on requirements set forth by 34 CFR Section 685.309(b)(2), the University is responsible for notifying the National Student Loan Data System (NSLDS) of changes to student’s enrollment data within minimum required timeframes. Cause: Controls are not functioning properly. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the withdrawal date was incorrectly reported as the last day of the term for four students and was not reported for one student. In addition, the R2T4 calculation was prepared untimely for four students that required a calculation, as noted in finding 2024-004, and thus the withdrawal dates were reported untimely. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend that a review process be put in place to ensure timely and accurate enrollment reporting to NSLDS. Corrective Actions: The policy to be developed regarding student withdrawals and R2T4 calculations will specify that students’ withdrawal dates are to be defined as the last date of academic attendance. The policy also will stipulate that, in accordance with National Student Clearinghouse requirements, Bluefield University will submit accurate student enrollment data throughout the academic year.

View Audit 344711

Finding 525613 (2024-004)

Significant Deficiency 2024

Bluefield University

VA

Reporting Student Financial Aid Significant Deficiency

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Return of Title IV Funds (Significant Deficiency) Condition: The University failed to return Title VI funds to the Department of Education within 45 days of student’s date of determina...

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Return of Title IV Funds (Significant Deficiency) Condition: The University failed to return Title VI funds to the Department of Education within 45 days of student’s date of determination. Criteria: Return of Title IV funds are required to be deposited or transferred into the SFA account or electronic fund transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR Section 668.173(b). Cause: Controls are not functioning properly. Effect: Funds were not timely returned to students or federal agencies as required. Context: From a population of 129 students that withdrew officially or unofficially during a term, we tested 12 students and noted that the R2T4 calculations were required for nine students. Of the nine students, R2T4 calculations were prepared untimely for six students, resulting in a late return of Title IV funds. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend procedures are put in place to ensure R2T4 calculations are performed timely following the University’s date of determination. Corrective Actions: In February 2025, Bluefield University leadership will work with the combined staff of the University’s Bluefield Central one-stop administrative office to develop and document a policy to ensure that communication from the registrar’s office regarding a student’s official or unofficial withdrawal occurs within 15 days of the student’s withdrawal. The policy also will stipulate that the financial aid staff of Bluefield Central will complete R2T4 calculations within 30 days of the student’s withdrawal, and the University’s business office will return Title IV funds to the Department of Education within 40 days of a student’s withdrawal.

View Audit 344711

Finding 525612 (2024-003)

Significant Deficiency 2024

Bluefield University

VA

Cash Management Reporting

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Cash Management Condition: Overdrawn federal student aid funds were not timely returned to the Department of Education. Criteria: In accordance with 34 CFR 668.162(b), a school may not...

U.S. Department of Education, Student Financial Aid Cluster – Assistance Listing # 84.033, 84.063, 84.007, 84.268 – Cash Management Condition: Overdrawn federal student aid funds were not timely returned to the Department of Education. Criteria: In accordance with 34 CFR 668.162(b), a school may not request more funds than the school needs immediately related to the disbursements the school has made or will make to eligible students and parents. A school must make the disbursements as soon as administratively feasible, but no later than three business days following the date the school receives those funds. Any funds not disbursed by the end of the third business day are considered excess cash. Cause: Lack of controls over cash management. Effect: Excess federal cash retained by the institution. Context: The University had overdrawn federal student aid funds of approximately $219,000 at June 30, 2024 related to draws that were made during June 2024. Repeat Finding from Prior Year: Not a repeat finding. Recommendation: We recommend the University implement appropriate training regarding compliance regulations into the employee onboarding process and thereafter for applicable employees. Additionally, we recommend the University implements timely review procedures to ensure that any overdrawn funds are returned within the tolerance period. Corrective Actions: In early October 2024, all staff from teh business office, student accounts, and financial aid met and developed a plan whereby they will be developing a calendar to include all key dates regarding student financial milestones. This calendar will include dates such as preregistration preliminary charge and financial aid posting dates, semester/term start dates, semester/term census dates, final charge posting dates, among other important dates. The team drafted this calendar in fall 2024 and implemented it effective January 2025.

View Audit 344711

Corrective Action Plans

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