Corrective Action Plans

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Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurate...
Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurately. Corrective Action Plan: The institution has taken and has fixed this issue by: • The system is now functioning correctly after addressing the issue with the vendor. • To prevent future issues, a more robust tool has been developed to identify discrepancies promptly should they arise. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Jennifer Service – Director of Financial Aid Anticipated Completion Date: 12/31/2025
Management acknowledges this finding. As a result of limitations in the SEFA preparation and reconciliation process during the prior fiscal year, certain FY2024 fourth-quarter expenditures were not properly accrued and were instead recorded in FY2025. In connection with the transition of key finance...
Management acknowledges this finding. As a result of limitations in the SEFA preparation and reconciliation process during the prior fiscal year, certain FY2024 fourth-quarter expenditures were not properly accrued and were instead recorded in FY2025. In connection with the transition of key finance staff, these expenditures were inadvertently included on the first draft of the Schedule of Expenditures of Federal Awards as a part of a federal award that had been fully expended and closed out the in the prior fiscal year. The error was identified and corrected during the audit. Vermont Land Trust has taken targeted steps to address the specific circumstances that resulted in this finding. Management performed a detailed review and reconciliation of active federal awards, including the award affected by fourth-quarter accrual activity, to confirm proper period recognition and award closeout status. As a result, the fully expended award was appropriately removed from the SEFA during the audit. To prevent similar issues during periods of staff transition or year-end close, management has implemented additional review procedures focused on fourth-quarter federal expenditures and accruals.These procedures include verification of award status prior to SEFA preparation and reconciliation of SEFA amounts to the general ledger and grant tracking records. Management believes these targeted actions appropriately address the conditions identified in the finding, and based on subsequent review, no similar issues have been identified. Planned Implementation Date of Corrective Action: Implemented during FY2025 Person Responsible for Corrective Action: Tracy Zschau, President & CEO
Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as ...
Findings – Federal Award 2025-001 Finding – Federal Award – Significant Deficiency in Internal Control over Compliance - Reporting Context: The Department of Housing and Urban Development (HUD) requires a Performance Report to be submitted, which must include a completed Federal Financial Report as an attachment. The required Progress Report was filed timely and accepted by HUD, however the required Federal Financial Report was omitted from the submission. Recommendation: The entity should implement and document internal controls to ensure all required reports are prepared, reviewed, and submitted in accordance with federal award requirements. Action Taken: To address the root cause and ensure strict adherence to federal reporting standards moving forward, the Finance Department has implemented the following internal controls, effective immediately: 1. Implementation of a Pre-Submission Checklist: A mandatory "Federal Reporting Checklist" has been developed. This document requires the preparer to physically check off that all required attachments—including narrative progress reports and financial reports (SF-425)—are present and accurate prior to upload. 2. Staff Training: Relevant staff members involved in the grant reporting process have been retrained on the specific submission requirements for HUD awards to ensure clarity on all deliverable components. Responsible Official: Rambod Behnam, Director of Finance Planned Completion Date: June 30, 2026.
The City concurs with the finding. Audit testing identified no reporting errors, no noncompliance, and no questions costs; however, the City acknowledges that documentation of independent supervisory review was not formally required or retained prior to submission of federal reports and reimbursemen...
The City concurs with the finding. Audit testing identified no reporting errors, no noncompliance, and no questions costs; however, the City acknowledges that documentation of independent supervisory review was not formally required or retained prior to submission of federal reports and reimbursement requests. To strengthen documentation of internal control over compliance, the City will implement a formalized and documented secondary review process for all federal financial reports, performance reports, and reimbursement requests, to be retained in grant files in accordance with CFR §200.334 record retention requirements.
Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disag...
Title: Student Financial Assistance Cluster – Assistance Listing Nos. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We identified that the issue is related to transferring data between NSC (where we report enrollment for all students) and NSLDS (where federal aid recipients are monitored). To bridge this gap, we have provided a member of the Registrar’s Office with access to NSLDS to audit the data submitted to NSC and the transfer of information. Additionally, we are conducting research to determine if there are alternative reporting options that may provide greater accuracy. Name(s) of the contact person(s) responsible for corrective action: Theresa Rodriguez Planned completion date for corrective action plan: March 2026
Corrective Action Plan The Central Columbia School District respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the Single Audit Report Year Ended June 30, 2025 included in the schedule of findings and questioned costs are discussed below. Fi...
Corrective Action Plan The Central Columbia School District respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the Single Audit Report Year Ended June 30, 2025 included in the schedule of findings and questioned costs are discussed below. Finding 2025-001: Reporting Contact Person: Steven Dolak, Business Administrator Recommendation: The District should revise procedures to ensure the data entered into the claim for reimbursement is reviewed for accuracy prior to the report being submitted. Evidence of the approval of submission should be documented in writing, such as with an initial, to demonstrate the review of the information has been performed. Action: The Business Administrator will prepare the reports for submission. Prior to submitting the report through the reimbursement system, a second individual will review the information entered. Upon satisfactory completion of the review, the second individual will acknowledge review by initialing and dating the document(s). Date for Completion: This procedure will be implemented at the beginning of the 2025-26 school year.
Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit find...
Finding Number: 2025-001 Federal Program: U.S. Department of Education – Student Financial Assistance Cluster Assistance Listing Numbers: 84.063, 84.007, 84.268, 84.033 Compliance Requirement: Special Tests and Provisions – Enrollment Reporting Finding Summary: The College agrees with the audit finding and is committed to strengthening internal controls over enrollment status reporting to ensure continued compliance with federal requirements. During management’s review of the audit results, the Registrar’s Office was unable to reproduce the specific enrollment status reporting errors identified during audit testing and could not definitively determine how the errors occurred. Notwithstanding this, the College recognizes that weaknesses in monitoring and documentation contributed to the inability to detect and prevent the reporting discrepancies in a timely manner. Accordingly, management has developed the following corrective actions. The College will enhance coordination among Registrar’s Office, Financial Aid, and Information Technology to ensure enrollment status changes including graduation, withdrawal, and changes in enrollment status are identified promptly and reported accurately to the National Student Loan Data System (NSLDS) within the required 60-day timeframe in accordance with 34 CFR 690.83(b)(2) and 34 CFR 685.309. For over 20 years, the College of Idaho has been a member of the National Student Clearinghouse (NSCH). One of the many advantages of membership to the NSCH is that the NSCH serves as a conduit to NSLDS and sends reports to the NSLDS for the college. Ellucian Colleague has written a series of reports that result in a .txt file that is uploaded to NSCH who in turn uploads to NSLDS. The College of Idaho submits regular transmissions to NSCH so that the 60-day timeframe is met. Corrective Action Plan: • Process Review and Clarification of Roles The Registrar’s Office will review and formalize procedures related to enrollment status determination and reporting. Roles and responsibilities for identifying enrollment changes, preparing NSLDS files, and submitting updates will be clearly documented to ensure accountability and continuity. • Student Information System Reporting Improvements The College will refine and validate student information system (SIS) reports used for enrollment reporting to ensure accurate capture of enrollment status changes and effective dates. Reports will be reviewed regularly to confirm continued reliability. • Internal Review and Oversight Controls Prior to submission to NSCH, enrollment status reports will be reviewed by the Registrar supervisory personnel to confirm accuracy and completeness. Evidence of review will be retained in accordance with institutional record retention practices. • Established Reporting Timeline A recurring reporting calendar will be implemented to ensure enrollment status updates are submitted within required federal timeframes. Backup personnel will be identified to support continuity during staff absences. • Training and Ongoing Communication Staff involved in enrollment reporting will receive periodic training on federal enrollment reporting requirements and institutional procedures. Regular communication between Enrollment Services and Financial Aid will support timely identification and resolution of discrepancies. Responsible Official(s): Mark Heidrich (Registrar/Associate Vice President for Institutional Effectiveness), in coordination with Stephanie House (Director of Financial Aid) and Imad Sweidan (Chief Information Officer), as appropriate. Anticipated Completion Date: June 30, 2026 Current Status: Corrective action is in progress. Management expects these actions to be fully implemented prior to the next audit period and believes the strengthened controls will prevent recurrence of this finding.
Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be...
Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be submitted. This process will help ensure continued accuracy and compliance in federal reporting.
The Organization will reinforce its filing control environment by implementing a documented reporting calendar and assigning responsibility to finance leadership for reviewing and certifying timely submission of future single audit reporting packages.
The Organization will reinforce its filing control environment by implementing a documented reporting calendar and assigning responsibility to finance leadership for reviewing and certifying timely submission of future single audit reporting packages.
In order to maintain procedures to verify the disbursement dates in the COD System agree to the date funds are credited to the student’s account in the colleges Accounts Receivable subledger to the general ledger, the institute has updated its procedures. The Financial Aid Office will adjust the sch...
In order to maintain procedures to verify the disbursement dates in the COD System agree to the date funds are credited to the student’s account in the colleges Accounts Receivable subledger to the general ledger, the institute has updated its procedures. The Financial Aid Office will adjust the scheduled disbursement date according to updated procedures when disbursement occurs earlier than the scheduled date to ensure accuracy of reporting data to COD. These are updates to the current Disbursement Policy and Procedures.
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding:...
Recommendation: We recommend the College review its reporting procedures to ensure the students' statuses are accurately reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Financial Aid Office updated procedures when citizenship documentation is received for a student previously classified as a noncitizen. The Financial Aid Office will notify the Office of Records and Registration of the student’s status change. Prior to disbursing Title IV aid, the Financial Aid Office will verify with the Office of Records and Registration that the student has been added to required NSLDS reporting. Name(s) of the contact person(s) responsible for corrective action: Tasha Marwitz Planned completion date for corrective action plan: Effective immediately.
Finding 2025-002: MAINTENANCE OF EFFORT – SIGNIFICANT DEFICIENCY Federal Program: Title I, Part A (84.010) Auditee Contact Person: James Ragsdale, CFO Expected Completion Date: July 31, 2026 Condition: The School’s Form 9 report, used by the IDOE to calculate Maintenance of Effort, was found to be u...
Finding 2025-002: MAINTENANCE OF EFFORT – SIGNIFICANT DEFICIENCY Federal Program: Title I, Part A (84.010) Auditee Contact Person: James Ragsdale, CFO Expected Completion Date: July 31, 2026 Condition: The School’s Form 9 report, used by the IDOE to calculate Maintenance of Effort, was found to be unreliable. Reported expenditures on the Form 9 did not reconcile with the Network’s cash-basis financial records for the period of July 1, 2024, to June 30, 2025. Corrective Action Plan: To ensure accurate reporting and compliance with Federal MOE standards, Purdue Polytechnic High School of Indianapolis, Inc. will implement the following: Form 9 Reconciliation Protocol: The School will implement a mandatory reconciliation between the general ledger cash-basis reports and the Form 9 Biannual Financial Report prior to each submission (January and July). Standardized Chart of Accounts: The CFO will review all account mappings to ensure they strictly follow the SBOA Uniform Compliance Guidelines for Indiana Charter Schools. This will ensure expenses are categorized correctly by fund, object, and function as required for IDOE reporting. Quarterly Internal Audits: The Finance Team will perform a Form 9 reconciliation quarterly to identify and correct any discrepancies in cash-basis recording before the official reporting window opens. Staff Training: The CFO will attend IDOE Office of School Finance training sessions specifically focused on Form 9 submission and Maintenance of Effort compliance. Audit Trail Documentation: For every Form 9 submission, the CFO will maintain a "reconciliation folder" containing the original trial balance and the crosswalk used to generate the Form 9.
Finding 2025-001 – Timely Preparation of Monthly Grant Expenditure Reports Name of the Contact Person Responsible for the Corrective Action Pan – Harold Ford, Vice President-Finance Corrective Action Plan – During the fiscal year ended June 30, 2026, the Organization has implemented procedures to en...
Finding 2025-001 – Timely Preparation of Monthly Grant Expenditure Reports Name of the Contact Person Responsible for the Corrective Action Pan – Harold Ford, Vice President-Finance Corrective Action Plan – During the fiscal year ended June 30, 2026, the Organization has implemented procedures to ensure monthly grant expenditure reports were submitted on a timely basis. Anticipated Completion Date – Completed for fiscal year end June 30, 2026
The district has updated procedures to include review of the Quarterly Financial Summary reports by someone other than the preparer of the reports prior to submission. Review will be documented. This finding was corrected in time for the 2nd Quarterly Financial Summary reporting (Oct-Dec 2024). Due ...
The district has updated procedures to include review of the Quarterly Financial Summary reports by someone other than the preparer of the reports prior to submission. Review will be documented. This finding was corrected in time for the 2nd Quarterly Financial Summary reporting (Oct-Dec 2024). Due to the timing of the 2024-25 Single Audit, the 1st Quarterly Financial Summary had already been submitted under the old process, which resulted in this finding to be a repeat of a prior year finding.
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Cause: Within the University's student information system, PowerCampus, the degree verifier report was not cros...
Finding – Special Tests and Provisions: Enrollment Reporting – Federal Direct Student Loan Program, Assistance Listing Number 84.268; June 30, 2025 Award Year; U.S. Department of Education Cause: Within the University's student information system, PowerCampus, the degree verifier report was not cross referenced with the graduation report. This student was on the degree verifier report but did not appear on graduation report, which is the report that is sent to the National Student Clearinghouse ("NSC") who then transmits information to NSLDS on behalf of the University. Condition: One student was excluded from the report used for the Clearinghouse as a graduated student. As they did not appear on the report twice, the Clearinghouse changed their status to withdrawn. The School then became aware of the change and the graduated status was transmitted to the clearinghouse on 2/7/25 and not received by NSLDS until 7/24/25. Criteria: The Enrollment information, including the effective date of separation from the institution, must be accurately reported within 30 days whenever attendance changes for a student, unless a roster will be submitted within 60 days. The changes include reductions or increases in attendance levels, withdrawals, graduations, and approved leaves of absence. It is the institution’s responsibility, as a participant in the Title IV aid programs, to monitor and report these changes to the National Student Loan Data System (“NSLDS”). (NSLDS Enrollment Reporting Guide November 2022, and 34 CFR 685.309(b)) Corrective Action Plan to be Taken: After each graduation period the Registrar’s Office will compare the Degree Verify file against the Graduation Enrollment file as both files are uploaded to the National Student Clearinghouse. The Degree Verify file is generated and uploaded after the Graduation Enrollment file; this process of report comparison will allow us to capture any student not reported in the Graduation Enrollment file. Thereby ensuring all graduating students are reported correctly to the National Student Clearinghouse. We’ll begin this process, on October 3, 2025 with the August 2025 graduates as they were just reported to the National Student Clearinghouse this past month. Sincerely, Linda M. Arce Registrar
To enhance compliance and oversight, the Northeastern State University Grant Office has implemented a mandatory dualphase training protocol for all Principal Investigators (PIs). Starting Fiscal Year 2026, all PIs are required to complete an inital compliance training upon award initiation. Furtherm...
To enhance compliance and oversight, the Northeastern State University Grant Office has implemented a mandatory dualphase training protocol for all Principal Investigators (PIs). Starting Fiscal Year 2026, all PIs are required to complete an inital compliance training upon award initiation. Furthermore, to address findings regarding reporting timelines, the university will conduct annual refresher training for all PIs with active awards. This annual session will specifically emphasize regulatory requirements for the timely submission of technical and financial reports.
Personnel turnover within the Office of the Registrar (July 2023) and the AVP for Academic Affairs (June 2024) led to procedural gaps during these transitions. Some of the proccesses and procedures suffered from a lack of transitional clarity. The Office of the Registrar is responsible for updating ...
Personnel turnover within the Office of the Registrar (July 2023) and the AVP for Academic Affairs (June 2024) led to procedural gaps during these transitions. Some of the proccesses and procedures suffered from a lack of transitional clarity. The Office of the Registrar is responsible for updating the STVMAJR screen in Banner which is a manual process. To rectify this, we have created a streamlined process for updates to the curriculum workflow to ensure precise alignment between Banner and CIP codes. This includes a new monthly meeting between the Registrar, Associate Registrar and AVP to review all curriculum updates, modifications, and new programs to prevent future errors. Issues with the Fall 2024 degree file delayed First of Term processing for Spring 2025. A defect introducted by an Ellucian update affected the degree file output and was resolved by updating the Banner page STVACAT (specifically the NSC Credential Level Translation column). This issue is not expected to recur. Spring 2025 First of Term processing was also delayed due to the manual creation of approximately 200 Social Security Numbers for newly admitted international students following the SLATE implementation and Admissions staffing turnover. This process has since been automated through an update to an Argos generator, eliminating the need for manual SSN creation. In addition, the National Student Clearinghouse transmission schedules were updated to allow additional processing time between files and to avoid submissions during the winter break. Specifically, transmissions for Fall Subsequent of Term were moved from January 1 to January 11, Fall Graduates Only (WS) from January 4 to January 18, and the Fall Degree file from January 14 to January 25.
Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager has begun the process of uploading the file that specifies disbursement date in the ledger so they match one another.
Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager has begun the process of uploading the file that specifies disbursement date in the ledger so they match one another.
The Chief Financial Officer will ensure staff retain documentation of the review and approval of grant reports prior to being submitted, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of the review and approval of grant reports prior to being submitted, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediatel...
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediately, January 30, 2026.
Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review credit balance refund processes, including automated processes, to ensure all credit balances are paid timely. Explanation of disagreement with audit finding...
Student Financial Assistance Cluster Assistance Listing No. 84.007, 84.033, 84.063 & 84.268 Recommendation: We recommend the University review credit balance refund processes, including automated processes, to ensure all credit balances are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Revised the daily Title IV credit balance workflows to include credit balances of any amount. Name(s) of the contact person(s) responsible for corrective action: Valerie Marsh, Director of Student Financial Services Planned completion date for corrective action plan: December 1, 2025
Material Weakness: 2025-001 Incomplete Year-End Closing Procedures: As stated in the findings the District did not complete its year end closing process for the fiscal year. Account reconciliations were incomplete, and financial statement accounts were not properly reconciled to detailed cost report...
Material Weakness: 2025-001 Incomplete Year-End Closing Procedures: As stated in the findings the District did not complete its year end closing process for the fiscal year. Account reconciliations were incomplete, and financial statement accounts were not properly reconciled to detailed cost reports. To rectify the material weakness moving forward, the District is actively advertising for an accountant position as an addition to the Business Department. Interviews are being scheduled, and the most qualified candidate will be recommended for hire by the Board of Directors. The accountant will be performing the reconciliations of all accounts prior to the close-out at year end. A spreadsheet detailing the reconciliations for all accounts will be implemented and utilized moving forward. This will become part of the close-out process prior to beginning the audit.
Response and Corrective Action Plan prepared by: Leanne Green Person Responsible for Implementing the Corrective Action: Leanne Green Anticipated Completion Date of Corrective Action: Vickie Dunaway, School Nutrition Director, corrected and resubmitted the claim in question, as soon as the issue was...
Response and Corrective Action Plan prepared by: Leanne Green Person Responsible for Implementing the Corrective Action: Leanne Green Anticipated Completion Date of Corrective Action: Vickie Dunaway, School Nutrition Director, corrected and resubmitted the claim in question, as soon as the issue was revealed. USDA paid the difference owed on October 28, 2025. Planned Corrective Action: Once the School Nutrition Director completes the monthly claim, Leanne Green, Finance Director, reviews the paperwork, verifying that all is correct before the claim is filed.
Identification Number: 2025‑003 – Enrollment Reporting (Repeat Finding) Finding: The University did not report one student status change timely and reported inaccurate program‑level record data for four students, resulting in inaccurate or untimely enrollment reporting to the U.S. Department of Educ...
Identification Number: 2025‑003 – Enrollment Reporting (Repeat Finding) Finding: The University did not report one student status change timely and reported inaccurate program‑level record data for four students, resulting in inaccurate or untimely enrollment reporting to the U.S. Department of Education. Corrective Action Plan: Management agrees with the finding. The University will enhance controls over enrollment reporting to ensure all student status changes and program‑level data are reviewed for accuracy and reported timely. Additional reconciliation between the Registrar's Office and Student Financial Services will occur before submission to the National Student Clearinghouse and the U.S. Department of Education. Responsible Officials and Implementation Date: The Registrar and Director of Student Financial Services will be responsible. Improved review and reconciliation procedures will be implemented by July 1, 2026, prior to the Fall term.
Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Jessica Johnston, Chief Financial Officer Anticipated Completion Date: August 20, 2025, immediately following the determination that the number o...
Finding Number: 2025‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Jessica Johnston, Chief Financial Officer Anticipated Completion Date: August 20, 2025, immediately following the determination that the number of meals reported for reimbursement for the January and March claims did not agree to supporting documentation. Planned Corrective Action: The District has modified its internal controls related to child nutrition claims. The revised procedures include a secondary verification of reimbursable meals, which is completed and submitted by personnel independent of the data entry process.
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