Corrective Action Plans

Finding 512337 (2024-002)

Material Weakness 2024

MI

School Nutrition Programs Internal Control / Segregation of Duties Material Weakness

Finding 2024-002 - Material Weakness: Budget Violations Corrective Action: The Finance Director and Business Office will undergo additional training with Tyler Technologies, Michigan School Business Officials and others to optimize financial processes and transaction processing. The team will adhere...

Finding 2024-002 - Material Weakness: Budget Violations Corrective Action: The Finance Director and Business Office will undergo additional training with Tyler Technologies, Michigan School Business Officials and others to optimize financial processes and transaction processing. The team will adhere to the state business calendar for timely reconciliations, budget amendments, and internal control reviews. Responsible Person: Director of Finance

View Audit 330083

Finding 512300 (2024-007)

Material Weakness 2024

Richland County Housing Authority

MT

Material Weakness Reporting Matching / Level of Effort / Earmarking

Finding 2024-007: Year End Reporting Rural Rental Housing Loan-10.415 Noncompliance/Material Weakness: AGREED RCHA Administration agrees it is responsible for completing and submitting Form RD 3560-7, Form RD 3560-10 and Attachment 4-F, Performance Standards Borrower Self-Certification letter, wi...

Finding 2024-007: Year End Reporting Rural Rental Housing Loan-10.415 Noncompliance/Material Weakness: AGREED RCHA Administration agrees it is responsible for completing and submitting Form RD 3560-7, Form RD 3560-10 and Attachment 4-F, Performance Standards Borrower Self-Certification letter, within 90 days following the close of the project year end. RCHA does believe these forms were presented to USDA representatives for the program, and was refused due to RD personnel believing RCHA was using the wrong fiscal year. This issue lasted many months and only after a change of USDA personnel and contact with the fee accountant and auditor, was the issue resolved. Corrective Action: RCHA Administration will have forms completed accurately and presented to those required immediately and will keep thorough copies of those items. RCHA continues to have issues with the MINC program, including approvements for timely payments. Corrective Action: RCHA Administration will complete forms and turn them into USDA personnel on time and accurately. Policies and procedures will be clear, approved and monitored by the Board of Commissioners, and completed by RCHA Administration before June 29th each year. This action will be completed immediately.

View Audit 330072

Finding 512212 (2024-002)

Significant Deficiency 2024

Texas Wesleyan University

TX

Student Financial Aid Reporting Questioned Costs

Finding: 2024-002 Enrollment Reporting Responsible Party: Dr. Karen Jarrell, Director of Office of Student Records and Registrar Completion Date: December 30, 2024 The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data ...

Finding: 2024-002 Enrollment Reporting Responsible Party: Dr. Karen Jarrell, Director of Office of Student Records and Registrar Completion Date: December 30, 2024 The Deputy Registrar from the Office of Student Records (OSR) is responsible for enrollment reporting to the National Student Loan Data System (NSLDS). The university uses a servicer, National Student Clearinghouse (NSC) to complete the reporting requirement. Enrollment data is scheduled to be transmitted to the NSC every thirty days to ensure timely reporting to the National Student Loan Data System (NSLDS). The University has consistently met this 30-day reporting to NSC. The audit noted four students had incorrect program start dates in NSLDS from April 2022 and August 2022, each off by one day. The University’s Student Information System (SIS) reflects the correct program start dates, indicating a potential issue in the data transmission between NSC and NSLDS. In July 2022, several announcements were made concerning the technical issues with NSLDS which prevented reporting for periods of time, including “NSLDS Professional Access – Documentation of Enrollment Reporting and Post-screening Delays for Audit Purposes” published on August 31, 2022. The audit noted three errors related to timely reporting. The university’s SIS records indicate these records were reported to NSC within the 30-day timeframe. However, these records were not transmitted from NSC to NSLDS timely. The Deputy Registrar is currently collaborating with the NSC Compliance division to determine the cause of these discrepancies and how best to correct the records in NSLDS. A response from NSC is anticipated by October 31, 2024. The audit also noted three students who were less than full-time that were not reported to NSC or NSLDS. The Deputy Registrar is researching the SIS system rules to determine the root cause of these errors so they can be corrected. The Deputy Registrar will ensure the reporting rules will be corrected by November 30, 2024, and will ensure any less than full time students are corrected in NSLDS by December 30, 2024. To enhance the enrollment reporting process, the Deputy Registrar, Registrar, and Director of Financial Aid will meet with NSC staff and IT staff to establish a method for comparing monthly data submitted to NSC with the data in the NSLDS system. This will help identify any discrepancies for immediate correction. This project is expected to be completed by December 30, 2024.

View Audit 329972

Finding 512207 (2024-001)

Significant Deficiency 2024

Texas Wesleyan University

TX

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Finding: 2024-001 R2T4 Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: November 30, 2024 With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The Universi...

Finding: 2024-001 R2T4 Responsible Party: Douglas Cleary, Director of Financial Aid Anticipated Completion Date: November 30, 2024 With the new Financial Aid leadership, the university has already implemented many new strategies to strengthen the Return of Title IV Funds (R2T4) process. The University created a new position, Financial Aid Business Analyst, whose primary responsibility is to maintain financial aid systems, maintain process documentation and provide staff system training and to oversee the R2T4 process. The Financial Aid Business Analyst has two years of previous experience being responsible for R2T4 calculations, completed the National Association of Student Financial Aid Administrators (NASFAA) R2T4 five-week certification program on October 14, 2024, and is in the process of training a Financial Advisor in performing R2T4 calculations. Other areas that have been identified will improve the R2T4 process are as follows: 1. Earlier Availability of the Academic Calendar: The Financial Aid Office leadership (Director, Assistant Director, Financial Aid Business Analyst) will work with the Office of Student Records (Registrar and Deputy Registrar) to ensure that there is an accurate R2T4/academic calendar. Both offices will work to develop such calendars with a clear description of the dates the University is closed for students, and that calendars can be developed years in advance. This will facilitate accurate determination of begin/end dates, break days and the total number of class days within any term. This will also encourage greater levels of transparency and oversight by both offices. The R2T4/academic calendar will also be shared with the Student Accounts Office, adding additional transparency and understanding. Timeline: The calendar for the Spring semester 2025 and the 2025-2026 academic calendar has already been developed and approved. The 2026-2027 academic calendar has been submitted to faculty for their input and will be completed by November 30, 2024. 2. Daily Percentage Calculator: The Financial Aid Business Analyst developed a daily percentage calculator that, implemented for Fall 2024, when combined with the academic calendar, will enable the accurate input of all term dates to generate precise daily percentage calculations for R2T4 purposes. This is also being expanded to create sub-term daily percentage calculations to eliminate the need for manual completion with each module-type calculation. 3. Post-Withdrawal Disbursements: The Financial Aid Business Analyst worked with Information Technology to ensure required communications related to R2T4 including post withdrawals (PWD) are now an automated process after completion of the calculations. This automation was implemented in August 2024. The PWD findings in this audit were the work by previous leadership within the Financial Aid Office. 4. Collaboration with IT for Updated Reporting: Financial Aid Office leadership (Financial Aid Business Analyst, Director) are collaborating with the IT to develop updated reports that will help accurately identify students who have unofficially withdrawn and require review during the R2T4 process. This initiative aims to create a preventive control that identifies errors and ensure timely calculations. The timeline for completion of the updated report is November 30, 2024. 5. Strengthening Internal Controls: The Director of Financial Aid has identified a Financial Aid Advisor who is currently being trained on R2T4 process, and who will eventually assume the primary responsibility for R2T4 calculations. The Financial Aid Business Analyst will provide secondary reviews to ensure accuracy and consistency. Note: The two PWDs from the Fall 2023 semester highlight a significant oversight by previous financial aid leadership. The inadvertent miscalculation of break days stemmed from confusion about the academic calendar. It appeared to suggest that students were required to attend classes on the weekend proceeding Thanksgiving week, while in reality, classes concluded the prior Friday. As a result, the Fall break should have been calculated as 9 days instead of 7.

View Audit 329972

Finding 512199 (2024-001)

Significant Deficiency 2024

Up Academy Charter School of Boston and Up Academy Charter School of Dorchester

MA

Reporting Subrecipient Monitoring

October 29, 2024 Department of Education UP Academy Charter School of Boston and UP Academy Charter School of Dorchester respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Str...

October 29, 2024 Department of Education UP Academy Charter School of Boston and UP Academy Charter School of Dorchester respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: The findings from the schedule of findings and questioned costs for the year ended June 30, 2024 are discussed below. The finding IS numbered consistently with the number assigned in the schedule. SIGNIFICANT DEFICIENCY AND MATERIAL INSTANCE OF NON-COMPLIANCE DEPARTMENT OF EDUCATION 2024-01 COVID-19 - Education Stabilization Fund Assistance Listing Number 84.425 Recommendation: AAFCPAs recommends that management follows its internal controls as intended to ensure the annual performance report agrees back to the Schedule of Expenditures of Federal Awards. Action Taken: Management has implemented an annual review of grant profit and loss statements to ensure that all Federal grants have no net income at the end of the fiscal year, completed by the Chief Financial Officer in conjunction with the rest of the finance team. Financial reports submitted externally will be agreed to the audited financial statements If the Department of Education has questions regarding this plan, please call Ashley Hutchinson O’Connor at (603) 553-2332. Sincerely yours, Ashley Hutchinson O’Connor Chief Financial Officer UP Education Network

View Audit 329959

Finding 512157 (2024-002)

Significant Deficiency 2024

Casper/natrona County International Airport

WY

Reporting

2024-002 Reporting Program Airport Improvement Program Name of Contact Person Tatum Hlavacek, Deputy Director of Finance Corrective Action Plan Casper/Natrona County International Airport submitted the required reports as soon as they were aware they had not been filed. Additionally, project engin...

2024-002 Reporting Program Airport Improvement Program Name of Contact Person Tatum Hlavacek, Deputy Director of Finance Corrective Action Plan Casper/Natrona County International Airport submitted the required reports as soon as they were aware they had not been filed. Additionally, project engineers had submitted the required SF-425 report at project completion for each open grant completed in fiscal year 2024. Airport staff have implemented a process to remind staff of upcoming reporting deadlines as appropriate to ensure required reports are filed timely. Proposed Completion Date June 30, 2025

View Audit 329893

Finding 512151 (2024-001)

None 2024

Casper/natrona County International Airport

WY

Subrecipient Monitoring Reporting

2024-001 Reporting Program Airport Improvement Program Name of Contact Person Tatum Hlavacek, Deputy Director of Finance Corrective Action Plan Casper/Natrona County International Airport reviewed the reports submitted and filed a corrected form with the amounts reported on the appropriate account...

2024-001 Reporting Program Airport Improvement Program Name of Contact Person Tatum Hlavacek, Deputy Director of Finance Corrective Action Plan Casper/Natrona County International Airport reviewed the reports submitted and filed a corrected form with the amounts reported on the appropriate accounting basis. Airport staff will continue to enhance their understanding of the reports filed and the underlying accounting records used to support the information reported to ensure amounts reported in the future are accurate and on the correct basis of accounting as appropriate. Proposed Completion Date June 30, 2025

View Audit 329893

Finding 512135 (2024-006)

Significant Deficiency 2024

Connors State College

OK

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

Student Financial Assistance Cluster- Assistance Listing No. 84.268 Finding: The College did not have documentation that Direct Loan Reconciliation was performed. Context: During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented. Cause: Due t...

Student Financial Assistance Cluster- Assistance Listing No. 84.268 Finding: The College did not have documentation that Direct Loan Reconciliation was performed. Context: During our testing we identified the March 2024 Direct Loan Reconciliation was not timely performed and documented. Cause: Due to staff turnover, direct loan reconciliation for March 2024 was not performed timely. Recommendation: We recommend the College implement a formal review procedure to document that the direct loan reconciliations are performed on a timely basis each month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A formal review process was already in place. The issue came from the turnover in the FA department leading to a loss of access. This will be remediated moving forward with more than one FA staff having reporting access and knowledge of reconciliations. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 11/01/2024

View Audit 329878

Finding 512121 (2024-004)

Significant Deficiency 2024

Connors State College

OK

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 5 students that did not have documentation of exit counselin...

Student Financial Assistance Cluster- Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly have documentation of exit counseling notification. Context: During our testing of 40 students, we identified 5 students that did not have documentation of exit counseling notification. Cause: The College did not have proper procedures in place to ensure that notification of required exit counseling was sent to applicable students. Recommendation: We recommend the College 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: This is due to a loss of knowledge due to turnover within the FA department. Moving forward, knowledge about loan exit counseling will be disseminated to all FA staff to ensure there are no gaps causing a reoccurring issue. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 12/15/2024

View Audit 329878

Finding 512119 (2024-002)

Significant Deficiency 2024

Connors State College

OK

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Student Financial Assistance Cluster-Assistance Listing No. 84.007, 84.038, 84.063, 84.268 ...

Student Financial Assistance Cluster-Assistance Listing No. 84.007, 84.038, 84.063, 84.268 Finding: The College did not properly report student enrollment changes for students who received federal student aid to the National Student Loan Data System (NSLDS). Context: During our testing of 40 students, we identified 3 students that did not have their Program enrollment reported to NSLDS and 3 students that had Program enrollment effective dates that did not match institutional records. Cause: The College didn't have proper procedures in place to verify students' status in NSLDS matched the institution's records accurately. Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC will put in place procedures that will ensure that submissions are reported accurately. Name(s) of the contact person(s) responsible for corrective action: Tina Ballinger Planned completion date for corrective action plan: 01/01/2025

View Audit 329878

Finding 512117 (2024-001)

Material Weakness 2024

Mana Academy

UT

Questioned Costs Material Weakness Reporting

Management will provide the USBE with the correct the amount of ESSER funds expended by FTE categories, the number of FTE’s supported with ESSER funds and the total number of FTE positions on September 30, 2023.

View Audit 329874

Finding 512113 (2024-002)

Significant Deficiency 2024

Lutheran Social Services of South Dakota

SD

Questioned Costs Subrecipient Monitoring Reporting § 200.303

Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance - State Administered Programs Reporting Finding Summary: The FFATA report filed for Huron School District included the incorrect Subaward Obligation/Action Da...

Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.566 Program Name: Refugee and Entrant Assistance - State Administered Programs Reporting Finding Summary: The FFATA report filed for Huron School District included the incorrect Subaward Obligation/Action Date within the FFATA Subaward Reporting System. Corrective Action Plan: FFATA reporting requirements were reviewed after the 2023 single audit report was received to ensure management has the correct understanding of reporting terms. The report in question was prepared and filed during July 2023 which was prior to the 2023 single audit report being finalized. FFATA reports filed during April 2024 and May 2024 were properly filed. Responsible Individuals: Nathan Beyer, Emily Lyons Anticipated Completion Date: December 31, 2023

View Audit 329857

Finding 512111 (2024-002)

Material Weakness 2024

Indiana Economic Development Corporation

IN

Reporting § 200.303 § 200.329

We agree with the recommendation and as of October 2024 have implemented an additional layer of review, effective for the first round of reports filed for FY2025.

View Audit 329851

Finding 512076 (2024-004)

Significant Deficiency 2024

Eastern Oregon University

OR

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to sto...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely, and to store evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office will work with our IS department to rebuild the original PELL unreported disbursements. Any unreported disbursements greater than 7 days will be reported to the financial aid director, information systems, and the vice president for finance and administration via email from Fast. This will allow for a review and timely reporting. Name(s) of the contact person(s) responsible for corrective action: Jason Hibbert Planned completion date for corrective action plan: January 6, 2025.

View Audit 329796

Finding 512066 (2024-002)

Significant Deficiency 2024

Eastern Oregon University

OR

Student Financial Aid Matching / Level of Effort / Earmarking Reporting § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and ar...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033, 84.379 Recommendation: We recommend that the University implement a key control to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely, and to store evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Review of Banner job to check for errors in reporting format or potential junk data that could cause a report to be rejected. New drop and withdrawal codes that only pertain to post term withdrawals and will only be used for a post term withdrawal to allow the dates to match, are being discussed. As well as internal discussion about developing key control tracking to show evidence that the controls in place are being followed. Name(s) of the contact person(s) responsible for corrective action: Emily Sharratt Planned completion date for corrective action plan: December 13, 2024

View Audit 329796

Finding 512057 (2024-002)

Significant Deficiency 2024

Bradley University

IN

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

2024-002: U.S. Department of Education. Assistance Listing Numbers: 84.063 - Federal Pell Grant Program, 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes ...

2024-002: U.S. Department of Education. Assistance Listing Numbers: 84.063 - Federal Pell Grant Program, 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 685.309 requires that enrollment status changes for students be reported to the National Student Loan Data System (NSLDS) within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. In addition, schools are required to certify enrollment every 60 days, and respond within 15 days of the date that NSLDS sends a Roster file to the school or its third-party servicer. Errors must be corrected within 10 days. Cause: The University’s processes and controls did not ensure that student status changes were properly and timely reported to NSLDS. Effect: The errors were caused by National Student Clearinghouse's communication with NSLDS, as a result of the modernization of NSLDS in 2022. The University was told the errors would be fixed and there was nothing more they needed to do. The errors were not fixed. Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Views of responsible officials: There is no disagreement with the audit finding.

View Audit 329791

Finding 512056 (2024-001)

Significant Deficiency 2024

Bradley University

IN

Questioned Costs Reporting Significant Deficiency

2024-001: Student Financial Assistance Cluster. Assistance Listing Number: 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.16 states whenever an institution di...

2024-001: Student Financial Assistance Cluster. Assistance Listing Number: 84.268 - Federal Direct Student Loans. Criteria or specific requirement: The Code of Federal Regulations, 34 CFR 675.16 states whenever an institution disburses FWS funds by crediting a student's account and the result is a credit balance, the institution must pay the credit balance directly to the student as soon as possible, but no later than 14 days after the credit balance occurred on the account. Cause: The student's refund was set to be sent out on but it fell on Labor day it didn't get sent out until after the 14 days. Effect: The University is not in compliance with Department of Education requirements that all credit balances be paid directly to the student as soon as possible, but no later than 14 days after the credit balance occurred. Recommendation: We recommend the University implement a process to ensure that any credit balances arising from federal student financial aid are made within the 14 day time limit imposed by the Department of Education. Views of responsible officials: There is no disagreement with the audit finding.

View Audit 329791

Finding 512048 (2024-002)

Significant Deficiency 2024

Vermont State Colleges

VT

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

This was an isolated instance and attributed to the merger of three institution into one institution effective July 1, 2023. The registrar is monitoring the re-enrollment of students that have taken a leave of absences or have not enrolled in VTSU since the merger to identify additional errors and w...

This was an isolated instance and attributed to the merger of three institution into one institution effective July 1, 2023. The registrar is monitoring the re-enrollment of students that have taken a leave of absences or have not enrolled in VTSU since the merger to identify additional errors and will take appropriate action to correct them as the occur.

View Audit 329772

Finding 511963 (2024-001)

Significant Deficiency 2024

The Skillsource Group, Inc.

VA

Reporting § 200.303

Views of Responsible Officials: Upon review, the issues and errors stemmed from misclassification and oversight in the award review and categorization process, primarily due to the onboarding of a new accounting team for the organization. Moreover, the SEFA was not presented for review by agency man...

Views of Responsible Officials: Upon review, the issues and errors stemmed from misclassification and oversight in the award review and categorization process, primarily due to the onboarding of a new accounting team for the organization. Moreover, the SEFA was not presented for review by agency management before the presentation to the auditors. To correct for the future, management will implement the following corrective actions: Enhance and Expand Review Process for SEFA Preparation  Establish a checklist and review protocol to ensure that all funding awards are properly identified and classified before inclusion in the SEFA.  Conduct a secondary review of the SEFA by the Senior Vice President for Operations and the President and CEO before submission to the auditors. Cross-Referencing with Award Documentation  Implement a mandatory cross-referencing procedure to match each award’s Assistance Listing Number (ALN) with award documentation.  Require verification of funding sources, ensuring that only Federally funded awards are included on the SEFA.

View Audit 329715

Finding 511958 (2024-001)

Significant Deficiency 2024

Westminster University

UT

Student Financial Aid Reporting Significant Deficiency

Westminster University is deeply committed to supporting its students and ensuring compliance with the requirements of the Student Financial Assistance Cluster. We appreciate the feedback provided in the Schedule of Findings and Questioned Costs and have taken action to address the concern raised. O...

Westminster University is deeply committed to supporting its students and ensuring compliance with the requirements of the Student Financial Assistance Cluster. We appreciate the feedback provided in the Schedule of Findings and Questioned Costs and have taken action to address the concern raised. Our institution is dedicated to continuous improvement in both our financial aid processes and overall student support services. We have developed an action plan to address the issue identified: FINDING 2024‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a policy to ensure address changes for all semesters are reported timely. Response: There is no disagreement with this audit finding. Action Taken in Response to Finding: Based upon the definition provided of Section 34 CFR Section 685.309(b) (2), it is our understanding that we are required to report address changes only on enrolled students through the period where they are marked as either (W) Withdrawn or (G) Graduated status. Our policy is to report students’ most current home address with each enrollment submission a minimum of 14 dates per year (three of which are only for graduated students) which ensures compliance with the 60-day threshold. However, our current practices have not always ensured that the current main home address was the one supplied to the National Student Clearinghouse. We will immediately implement processes to ensure that the main home address is the one sent to the National Student Clearinghouse. We consider this to be remediated. Contact Person(s): Karen Henriquez, Director of Financial Aid

View Audit 329674

Finding 511947 (2024-002)

Significant Deficiency 2024

Summit Academy Oic

MN

Questioned Costs Student Financial Aid Reporting

Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with...

Recommendation: We recommend the Academy reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since the audit, Summit Academy has determined a new process in which we certify and make changes to the enrollment data found in NSLDS. Moving forward, the Financial Aid Manager will be assigned tasks within our operating system (Anthology) that will notify her of any students who withdrawal, go on a leave of absence, changed their enrollment intensity or graduate. The Financial Aid Manager will check this daily and update the students NSLDS enrollment data accordingly. The Financial Aid Manager will also keep a spreadsheet detailing the students name and the dates each student was certified. The Financial Aid Manager will also work closely with the Registrar’s Department to ensure the graduation and withdrawal lists are accurate. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO Planned completion date for corrective action plan: Fall 2024

View Audit 329672

Finding 511944 (2024-001)

Significant Deficiency 2024

Summit Academy Oic

MN

Questioned Costs Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with th...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Academy review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Summit has created a new process that includes duplicated training and support with the Financial Aid Manager and the Chief Financial Officer for ongoing monitoring and maintenance of the organization’s ECAR. The Financial Aid Manager and the CFO have a list of the listed Officers on the ECAR. In the event of any changes in staffing, including the listed officer and Financial Aid positions, those changes will be reported up through the ECAR by the Financial Aid Manager or, in the event that the Financial Aid Manager is part of the change, the reporting will be handled by the CFO. Name(s) of the contact person(s) responsible for corrective action: Marc Carrier, CFO Planned completion date for corrective action plan: Fall 2024

View Audit 329672

Finding 511942 (2024-002)

Significant Deficiency 2024

Lutheran Social Services of Central Ohio Mansfield Housing, Inc.

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Finding Number: 2024-002 Condition: The Corporation did not send HUD the approved residual receipts recapture requested by HUD in a reasonable period of time. The Corporation did not have a control in place to track that these funds were properly remitted to HUD. Planned Corrective Action: Managemen...

Finding Number: 2024-002 Condition: The Corporation did not send HUD the approved residual receipts recapture requested by HUD in a reasonable period of time. The Corporation did not have a control in place to track that these funds were properly remitted to HUD. Planned Corrective Action: Management is in the process of improving controls to ensure that all approved residual receipt recaptures requested by HUD are timely remitted to HUD. Contact person responsible for corrective action: Fikru Nigusse, CFO Anticipated Completion Date: June 30, 2025

View Audit 329671

Finding 511888 (2024-014)

Material Weakness 2024

Nevada System of Higher Education

NV

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report. This review process will in...

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. UNLV – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: UNLV Office of Sponsored Programs will work with PIs to ensure there is properly documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. • How compliance and performance will be measured and documented for future audit, management and performance review: Effective immediately, UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility along with applicable Deans. DRI – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: DRI will implement controls that require the documentation of review and approval on the invoice process. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full implementation of review procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Once the position is filled, all invoices will be reviewed prior to drawing down or requesting reimbursement of funds. Documentation will occur either through the business process in the accounting system or manually as needed. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. SA – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Future progress reports will require a review from a Director or higher supervisory approval prior to submission of reports to awarding sponsor/agency. • How compliance and performance will be measured and documented for future audit, management and performance review: Preparing department will provide either a signed version and/or email approval of progress report to the NSHE System Sponsored Programs to be filed with the award in Workday. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The NSHE System Sponsored Programs Director is responsible for remediation of this finding. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596

Finding 511786 (2024-020)

Significant Deficiency 2024

Nevada System of Higher Education

NV

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report, ensuring all information is...

UNR – Agrees with the finding. • Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place: Management staff, independent of the preparer, will review and sign off on each report, ensuring all information is correctly entered. Staff will also verify that all required FFATA (Federal Funding Accountability and Transparency Act) reporting is accurately completed and submitted in a timely manner. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured and documented through the independent review process, where management, independent of the preparer will verify and sign off on each report to ensure accuracy. These reviews will be tracked in Workday, with approvals and date stamps. A FFATA Entry Log will be maintained, documenting each submission. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for the reports. The Associate Director of PreAward is responsible for the FFATA. Name of contact person responsible for corrective action plan: Rhett R. Vertrees, Assistant Chief Financial Officer 2601 Enterprise Road, Reno NV 89512-1666 Phone: (775)784-3409, Fax: (775)784-1127 Email: rvertrees@nshe.nevada.edu

View Audit 329596

Corrective Action Plans

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