Corrective Action Plans

Finding 389373 (2023-004)

Significant Deficiency 2023

SC

Internal Control / Segregation of Duties Special Tests & Provisions Reporting

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the compliance requirements of General Disbursements. The rule requiring the University to wait 30 days before disbursing funds to first time borrowers if the institution does not meet the low default rate requirement must be adhered to and reviewed by the Office of Financial Aid with oversight from the new internal audit team. This will be a critical reporting area for both the Office of Financial Aid and the internal audit team. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389371 (2023-003)

Significant Deficiency 2023

South Carolina State University

SC

Internal Control / Segregation of Duties HUD Housing Programs Reporting

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies. Management and implementation of current corrective plans are critical to the compliance efforts of the University: To ensure that future reporting of the CARES HEERF funding is posted timely, and in the required format, the University’s Controller, Financial Aid Director and Vice President of Finance and Administration/Chief Finance Officer (CFO) will conduct a monthly review and/or periodically check the Department of Education CARES HEERF FAQs for updates and new requirements. This monthly review process will be overseen by the Assistant Provost for Sponsored Programs, who will function as a neutral third party. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. During the prior reporting periods under review, the University was in the process of submitting and seeking approval of a no-cost extension. During this same period that is under review, the University closed out the current “HEERF” grant and was awarded a “no-cost” extension from the Department of Education. In the University’s attempt to secure a “no-cost” extension from the Department of Education, the reporting schedules under review were developed but not posted to the University’s website as required. The oversight of the reporting process will be a key performance indicator for the internal audit team as we prepare for the “no-cost” extension phase of the grant. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389367 (2023-002)

Significant Deficiency 2023

South Carolina State University

SC

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated organizations. Management and implementation of current corrective plans are critical to the compliance efforts of the University: As stated in the previous corrective action plan the Registrar’s Office in coordination with the Information Technology Division has developed a “flag based” process to capture and monitor enrollment status changes. The implementation and proper reporting of these activities will be led the applicable team with oversight and assistance from the new internal auditing team. As this is a repeated finding, the University‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance/operation offices (Registrar’s Office and Academic Affairs Office). The University is requesting a report be filed on the status of this reporting requirement on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance our oversight and management of the corrective action plans through the new internal audit team until this matter has been resolved. The University embraces the recommendation to enhance its procedures and internal controls over the applicable compliance requirements of enrollment reporting to ensure that all status changes are submitted to NSLDS within the required timeframe. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389363 (2023-001)

Significant Deficiency 2023

South Carolina State University

SC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in t...

Corrective Action Plan: The University will take immediate action to address the findings of the audit report. As part of the University’s holistic program to improve compliance and assurance, the institution has requested a position number from the State of South Carolina Human Resource office in the area of internal auditing along with developing a budget line item for this operation. Moving forward, the new internal auditor position will provide needed leadership on all corrective action plans as necessary. The internal auditor will be the point of contact for all audit related matters, thus providing needed onsite management for compliance related issues for the University and its affiliated agencies. In an attempt to seek innovative measures to improve the procedures and internal controls, the Office of Financial Aid has engaged an external consultant to review all critical processes. This will be a fluid engagement, which will aim to self-assess the strength, weaknesses, opportunities, and threats to the efficiency of the department. Management and implementation of current corrective plans are critical to the compliance efforts of the University: The University has made the necessary changes to the staff and will continue to assess the efficiency of the review process to include, but not limited to, the hiring of both a Senior Financial Aid Counselor and a Director of Transfer Students. The new Director of Transfer Students will have the necessary access/ability to generate the information and update the system to improve the University’s capability to monitor requirements of Title IV aid to ensure enhanced compliance. This will eliminate the challenge created by multiple financial aid counselors being assigned the responsibility for initiating the process, generating the information, and updating the system on a weekly basis. In addition, the Director of Financial Aid will receive alerts when the process has been completed, and perform periodic reviews, using sample populations, to ensure the process is being done timely and accurately. As this is a repeated finding, the University ‘s corrective action plan will be of the upmost importance to the internal auditing team and all other compliance offices (Director of Financial Aid and Director of Transfer Students). The University is requesting a report be filed on the status of our transfer students on a semester basis until this matter has been resolved. The new internal audit team will be the lead management unit for this reporting cycle. In short, the University will enhance its oversight and management of the corrective action plans through the new internal audit unit until this matter has been resolved. Anticipated Completion Date: June 30, 2024

View Audit 300369

Finding 389359 (2023-001)

Significant Deficiency 2023

Molloy College

NY

Student Financial Aid Special Tests & Provisions Reporting

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University u...

Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Finding 2023-001 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Linda Albanese, Vice President Enrollment Management; lalbanese@molloy.edu; 516-323-4025 Molloy University understands the finding and has devised a process to ensure students who submit a request to withdraw which is effective after the completion of the current semester get processed manually in NSLDS once the semester has ended. To aid in this updated practice, a documented procedure has been established that provides a checklist of steps and collection of internal signatures to be completed for each student who indicates they wish to withdraw from the University. Additionally, we will be engaging a consultant to perform a compliance review with the US Department of Education for Enrollment Reporting. This will ensure that the withdrawal status is promptly provided within the required timeframe. Proposed completion date: February 20, 2024

View Audit 300357

Finding 389356 (2023-002)

Significant Deficiency 2023

Antioch University

OH

Special Tests & Provisions Student Financial Aid Period of Performance

Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment r...

Corrective Action Taken or Planned: The University has experienced changes in staffing for personnel involved in enrollment reporting and system irregularities with multiple programs with the National Clearing House. These inconsistencies have caused delays in processing and response to enrollment reporting changes. Antioch University has hired a new Director of Records Administration with a primary responsibility for NSLDS reporting. The University will implement a comprehensive training plan for new individuals and teams, including improved documentation of procedures, increased clarity regarding the process for the necessity of error resolution, and a review of system processing to help reduce errors in reporting and increase efficiency. In addition, internal reviews and control audits will be performed throughout the year to ensure accuracy in NSLDS reporting and alignment with the National Clearing House guidance. Person Responsible for Corrective Action: Maureen Heacock, the Registrar and Katy Stahl, Executive Director of Financial Aid & Scholarships are responsible for executing the corrective action plan. Anticipated Completion Date: Fiscal year 2024

View Audit 300356

Finding 389355 (2023-001)

Significant Deficiency 2023

Antioch University

OH

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action Taken or Planned: Starting with the 2024-2025 Award year, the Office of Financial Aid and Scholarships is undergoing an internal reorganization. The purpose of this is to provide a broader depth of knowledge and better dual control and compliance functions within the Office of Fina...

Corrective Action Taken or Planned: Starting with the 2024-2025 Award year, the Office of Financial Aid and Scholarships is undergoing an internal reorganization. The purpose of this is to provide a broader depth of knowledge and better dual control and compliance functions within the Office of Financial Aid and Scholarships. In the new reorganization structure, the FA Specialist will be responsible for performing the R2T4 Calculations, with their Supervisor, the Assistant Director of Financial Aid Operations, reviewing and approving the calculation. Once the calculation is completed, and signed off on by the Assistant Director, the FA Specialist will will complete and send the Financial Aid Transmittal Register (FATR) report and notify the Student Accounts Office so they can process the return of funds on through the Financial Aid Posting Register (FATP). Review of the Financial Aid Posting Register will be done by the FA Specialist to ensure the internal process to return funds is timely and posted to the Common Origination and Disbursement system accurately. A quarterly review and internal control audit of Title IV refund calculations will also be completed to ensure accuracy in system processing, days and break calculations, and adherence to Title IV regulations. In addition, the staff will have additional training throughout the year on Title IV compliance and refunds to ensure the University is compliant with all regulations. Person Responsible for Corrective Action: Katy Stahl, the Executive Director of Financial Aid & Scholarships, is responsible for the execution of the corrective action plan. Anticipated Completion Date: Fiscal year 2024

View Audit 300356

Finding 389354 (2023-002)

Significant Deficiency 2023

Economic Development and Industrial Corporation of Boston

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

EDIC will update its current internal controls for submitting subaward information to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and will create a new submission into FSRS each month to report any required subaward information in accordance with the prog...

EDIC will update its current internal controls for submitting subaward information to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and will create a new submission into FSRS each month to report any required subaward information in accordance with the program requirements.

View Audit 300355

Finding 389345 (2023-003)

Significant Deficiency 2023

Hht Foundation International, INC

MD

Questioned Costs Reporting § 200.303

The outsourced accounting firm will create and execute a year-end process that will analyze all payments made during the 60 days following the fiscal year-end to ensure that expenses are recorded in the correct fiscal year. This process will ensure the Schedule of Expenditures of Federal Awards (SEF...

The outsourced accounting firm will create and execute a year-end process that will analyze all payments made during the 60 days following the fiscal year-end to ensure that expenses are recorded in the correct fiscal year. This process will ensure the Schedule of Expenditures of Federal Awards (SEFA) is reported properly. The grant program manager will ask vendors to submit their invoices for services rendered through the fiscal year end to Cure HHT within 30 days of the fiscal year end. Each grant contract year differs from the Cure HHT fiscal year. Cure HHT will create and execute a grant reconciliation process that involves financial reporting from the outsourced accounting firm, members of the outsourced accounting team, Cure HHT grant managers, and Cure HHT management to validate that all cost reimbursable grants recognize revenue as costs are incurred. All parties will ensure appropriate accounting processes and controls are in place on an ongoing basis. The reconciliation process will take place monthly and at fiscal year-end.

View Audit 300345 Questioned Costs: $1

Finding 389344 (2023-002)

Significant Deficiency 2023

Hht Foundation International, INC

MD

Questioned Costs Cash Management Reporting § 200.303 § 200.305

This error occurred during a time of transition from one outsourced accounting firm and accounting system to another. The new outsourced accounting systems were not fully in place or automated at the time of the reporting error and there was no internal review process. The outsourced accounting firm...

This error occurred during a time of transition from one outsourced accounting firm and accounting system to another. The new outsourced accounting systems were not fully in place or automated at the time of the reporting error and there was no internal review process. The outsourced accounting firm is now fully transitioned, all systems are fully integrated with the accounting software, and the accounting team provides the program managers and organization managers with the reports needed to prepare drawdown requests. Cure HHT has developed and fully implemented a corrective action plan. The organization has communicated with the cognizant agency and all expenses eligible for submission for payment through grant funding will be submitted to and paid from the overdrawn funds. Once these funds are depleted, the organization will resume monthly draw submissions for all eligible expenses. The organization will reconcile all eligible expenses prior to requesting grant funds to avoid future duplicate and/or incorrect requests for grant funds. In addition, pending proper internal approvals of all submitted expenses, grant funds received will be dispersed within 3-7 business days from the date received.

View Audit 300345 Questioned Costs: $1

Finding 389343 (2023-004)

Material Weakness 2023

New Castle County, Delaware

DE

Subrecipient Monitoring Material Weakness Reporting § 200.303

MATERIAL WEAKNESS 2023-004 Community Development Block Grant/Entitlement Grants – Assistance Listing No. 14.218 Recommendation: We recommend that the County subsequently report the subawards not reported in FSRS. We further recommend the County strengthen controls and procedures to ensure that all r...

MATERIAL WEAKNESS 2023-004 Community Development Block Grant/Entitlement Grants – Assistance Listing No. 14.218 Recommendation: We recommend that the County subsequently report the subawards not reported in FSRS. We further recommend the County strengthen controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Community Services was made aware of the FFATA issue at the end of FY22. The Department developed and executed a Standard Operating Procedure (SOP) to ensure all awards over $30,000 were submitted to the FSRS system within the required time. In FY23 we entered the FY22 and FY23 sub-recipient awards in FSRS. In FY23 there were expenses for sub-recipient awards that were issued in FY20 and FY21, which was identified by CLA. The Department will modify our SOP to require all sub-recipient awards be entered regardless of the fiscal year they were awarded; this ensures accurate and up-to-date reporting. Name(s) of the contact person(s) responsible for corrective action: Mike Kapa Planned completion date for corrective action plan: June 30, 2024

View Audit 300342

Finding 389334 (2023-001)

Significant Deficiency 2023

Lake County Crisis Center D/b/a A Safe Place

IL

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding Personnel Responsible for Corrective Action: CFO and Accounting department staff Anticipated Completion Date: Completed September 2023 Corrective Action Plan: A Safe Place will implement internal control procedures to ensure t...

Finding 2023-001 – Significant Deficiency: Reporting - Compliance Finding Personnel Responsible for Corrective Action: CFO and Accounting department staff Anticipated Completion Date: Completed September 2023 Corrective Action Plan: A Safe Place will implement internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. Update: A Safe Place developed an infrastructure and implemented internal control procedures to ensure timely submission of all future reports. The CFO will review financial reporting prior to submission. The Program Administrative Manager will ensure all program performance reports (PPR) will be reviewed and submitted timely.

View Audit 300326

Finding 389332 (2023-002)

Material Weakness 2023

The Thresholds and Affiliated Organizations

IL

Reporting Material Weakness

Condition: An award passed through IDHS was not initially classified with the correct assistance listing number on the Schedule of Expenditures of Federal Awards (SEFA) by the Agency. The incorrect ALN was identified during audit procedures and corrected by the Agency. Planned Corrective Action: Thr...

Condition: An award passed through IDHS was not initially classified with the correct assistance listing number on the Schedule of Expenditures of Federal Awards (SEFA) by the Agency. The incorrect ALN was identified during audit procedures and corrected by the Agency. Planned Corrective Action: Thresholds will have a colleague outside of the Grants team (Controller or SVP for Finance) review future SEFAs. We will pay particular attention to ensure all expenditures are shown with the correct ALN, dollar amounts, and other fields. Contact person responsible for corrective action: Al Shoreibah, Chief Financial Officer Anticipated Completion Date: April 1, 2024

View Audit 300324

Finding 389331 (2023-001)

Material Weakness 2023

The Thresholds and Affiliated Organizations

IL

Material Weakness Reporting

Condition: The Organization's controls in place for reporting submissions did not identify Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements guidelines were not followed related to the lost revenue calculations. The Period 4 reporting submission for...

Condition: The Organization's controls in place for reporting submissions did not identify Provider Relief Fund General and Targeted Distribution Post-Payment Notice of Reporting Requirements guidelines were not followed related to the lost revenue calculations. The Period 4 reporting submission for lost revenue did not follow the acceptable options outlined by HHS. Additionally, the Period 2 reporting submission, completed in the previous year, did not follow the acceptable options. Planned Corrective Action: Thresholds will have a second individual (Controller or SVP for Finance) review future award applications that are one-time or unusual in nature. We will pay particular attention to review the terms carefully so that Thresholds does not misunderstand things (such as the acceptable options, as in this case). Contact person responsible for corrective action: Al Shoreibah, Chief Financial Officer Anticipated Completion Date: April 1, 2024.

View Audit 300324

Finding 389330 (2023-001)

Material Weakness 2023

Trihealth

OH

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking

Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF), Assistance Listing No. 93.498 Federal Agency: U.S. Department of Health and Human Services (HHS) Planned Responsible Officials: Mike Crofton, VP of Finance and Interim Chief Financial Officer C...

Federal Program: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF), Assistance Listing No. 93.498 Federal Agency: U.S. Department of Health and Human Services (HHS) Planned Responsible Officials: Mike Crofton, VP of Finance and Interim Chief Financial Officer Corrective Action: TriHealth is committed to ensuring internal controls are implemented to ensure compliance with Section 200.303 of the Uniform Guidance. In response to the findings, TriHealth has or will implement the following policies and procedures: 1. Design and implement controls over our any future PRF reporting, including both General Distributions and Targeted or Rural Distributions, to ensure the necessary documentation is submitted in the HHS Reporting Portal and that the information submitted is complete and accurate based on accounting records and other data. This will include retention of necessary documentation to support reported expenditures and lost revenues and that such documentation is reviewed by TriHealth’s Controller and VP of Finance and Interim Chief Financial Officer. 2. Utilize Internal Audit to perform detail review and testing over the PRF program reporting, as applicable. This will include the use of Internal Audit to review PRF reporting prior to submission to the HHS Portal, as well as appropriateness of lost revenue and allowability of healthcare related expenses. 3. Prior to submission, the Controller and the Executive Director of Internal Audit will review the draft reporting submissions with the Executive Director of Decision Support and Reimbursement prior to submitting the reports in the HHS Portal. As TriHealth and its affiliates did not receive PRF General Distributions in excess of $10,000, individually or in the aggregate, during PRF Reporting Period 6 (payments received from July 1, 2022 to December 31, 2022), TriHealth will not be required to submit any future reporting in the HHS Portal for PRF General Distributions. However, TriHealth will ensure appropriate levels of review occur for any future reporting of PRF or similar federal funding, including PRF Targeted or Rural Distributions.

View Audit 300321

Finding 389321 (2023-001)

Significant Deficiency 2023

Tougaloo College

MS

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding 2023-001 Reporting Compliance - U.S. Department of Education (USDE), Coronavirus Aid Relief, and Economic Security (CARES) Act Programs: (Significant Deficiency): We observed the following condition in connection with our testing of the various U. S. Department of Education, Coronavirus Aid ...

Finding 2023-001 Reporting Compliance - U.S. Department of Education (USDE), Coronavirus Aid Relief, and Economic Security (CARES) Act Programs: (Significant Deficiency): We observed the following condition in connection with our testing of the various U. S. Department of Education, Coronavirus Aid Relief, and Economic Security (CARES) Act Program: • There was no evidence provided regarding the submission of the annual and quarterly reports. Recommendation – We recommend that the College ensure reporting requirements are met for all grant programs. Corrective Action – The Office of Fiscal Affairs understands the importance of federal compliance. The U.S. Department of Education was contacted about the late filings. Under federal guidance, the Year 3 quarterly reports were submitted on the College website in January 2024. The annual report for Year 3 will be submitted in July 2024 when the U. S. Department of Education reopens the portal, Annual Report Data Collection Tool.

View Audit 300307

Finding 389292 (2023-002)

None 2023

Town of Rutland, Massachusetts

MA

Subrecipient Monitoring Reporting § 200.1

Condition: Obligations were overstated by $1,502,835 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: Obligations and commitments were mistakenly considered the same. A correction will take place with our next Annual Submission that is due April 2024. Anticipated Co...

Condition: Obligations were overstated by $1,502,835 on the March 31, 2023 Project and Expenditure report. Corrective Action Planned: Obligations and commitments were mistakenly considered the same. A correction will take place with our next Annual Submission that is due April 2024. Anticipated Completion Date: April 2024 Contact: Seth Knipe, Fire Chief

View Audit 300301

Finding 389283 (2023-002)

Significant Deficiency 2023

Early Learning Coalition of the Big Bend Region, Inc.

FL

Cash Management Reporting Internal Control / Segregation of Duties

Finding 2023-002: Internal Control over Compliance and Compliance with Cash Management Federal Programs ALN: 93.575, 93.596, 93.558 Criteria: In accordance with the grant agreement, and Division of Early Learning (DEL) Program Guidance 240.01, Cash Management Procedures, any advance that cannot be...

Finding 2023-002: Internal Control over Compliance and Compliance with Cash Management Federal Programs ALN: 93.575, 93.596, 93.558 Criteria: In accordance with the grant agreement, and Division of Early Learning (DEL) Program Guidance 240.01, Cash Management Procedures, any advance that cannot be expended or offset by September 18, must be returned to DEL by September 30 of the following year. Condition: The Coalition did not timely remit the unexpended advance related to the 2022-2023 fiscal year in compliance with the grant agreement and DEL Program Guidance. Cause: Lack of effective controls surrounding cash management and review of controls to ensure compliance with grant and DEL Program Guidance. Effect: The Coalition did not timely remit the unexpended advance related to the 2022-2023 fiscal year to DEL until January 8, 2024. Recommendation: We recommend the Coalition implement procedures to ensure that all advances are reconciled on a monthly basis and remitted to DEL in accordance with the grant agreement and DEL guidance. Corrective Action Plan: ELC Management will make sure that measures are in place to ensure all advances are reconciled monthly and paid timely back to DEL. Responsible Party: Felicia Milton, CFO Anticipated Completion Date: March 2024

View Audit 300296

Finding 389281 (2023-001)

Significant Deficiency 2023

Hagerstown Community College

MD

Matching / Level of Effort / Earmarking Student Financial Aid Subrecipient Monitoring § 200.303

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the num...

Hagerstown Community College respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 - June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS- FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster-Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status and effective date was reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Cause-Enrollment Status Reporting: Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely and correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses in NSLDS. No review was completed to ensure the upload was completed in NSLDS. Cause for Effective Date Reporting - Hagerstown Community College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student effective date corrections were uploaded to NSC correctly; however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate update of the status effective date NSLDS. No review was completed to ensure the upload was completed in NSLDS. The following actions have been implemented to resolve the deficiencies: The Director of Financial Aid has reached out to NSC to determine the errors in the file transmissions. NSC responded back with the issues that need to be research by HCC's Student Financial Aid Office and Registrar's office. Both offices will collaborate to identify the error and develop procedures to minimize the error from happening again. HCC plans to review the reporting procedures for withdrawn and graduating students. NSC sent HCC a detailed explanation of what needs to be reviewed to make sure the correct information is transmitted. Name(s) of the contact person(s) responsible for corrective action: Dr. Charles M. Scheetz, Director of Financial Aid and W. Christopher Baer, Registrar Planned completion date for corrective action plan: Summer 2024

View Audit 300295

Finding 388601 (2023-001)

Material Weakness 2023

Saint Louis University

MO

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.303 § 200.337 § 200.431

As noted in our prior year response, the University continued to have cost transfers in fiscal year 2023 as it reconciled its grants. To limit cost transfers in the future, the following steps have been taken by the University: • The Controller’s Office along with the Office of the Vice President of...

As noted in our prior year response, the University continued to have cost transfers in fiscal year 2023 as it reconciled its grants. To limit cost transfers in the future, the following steps have been taken by the University: • The Controller’s Office along with the Office of the Vice President of Research configured our accounting system with an automated control that prevents general (non-payroll) expenditures from being charged to the grant after the period of performance end date, one root cause of cost transfers. • For payroll expenditures, post-award specialists updated grant labor costing allocations in our accounting system to contain an end date that coincides with the period of performance end date. This change in Workday restricts labor costs from being charged after the period of performance. The University’s post-award specialist review grant labor costing allocations on a periodic basis. • With collaboration between the payroll department, the Controller’s Office and post-award specialists, before each payroll is processed within the accounting system, grants that have ended are identified and the payroll expenditures are removed from the feed and not charged to the grant. • On-going training on data certification by post-award grant managers has improved grant-expenditure compliance and data accuracy. In addition, the Controller’s Office implemented a process in which post-award grant managers are now reviewing grant level budget versus actual reporting on a periodic basis to identify errors timely (i.e. before the 90 day threshold). Additionally, the University’s Workday team is exploring additional functionality within our Workday grants management module to build in additional expense approvals, specifically for labor, before those expenses are charged to the grant to reduce future cost transfers. As part of the University’s corrective action plan, during fiscal year 2023 the sponsored programs accounting team recalculated fringe and indirect costs on all federal grants to ensure the correct expense was recorded to each grant. During this reconciliation process cumulative award to date errors were identified and corrected. The sponsored program accounting team continues to reconcile fringe and indirect costs on cost transfers at the grant level on a periodic basis to ensure accuracy. Tara Thomason, Controller and Assistance Vice President, is responsible for addressing the above items by June 2024.

View Audit 300294 Questioned Costs: $1

Finding 388573 (2023-006)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-006 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for ...

2023-006 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University incorrectly calculated institutional charges used in determining the amount of unearned aid to withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has recently made improvements to the process of completing the return to Title IV calculations. This was achieved by providing additional training and workshops offered through the Department of Education. Furthermore, we have also developed a spreadsheet to assist with calculating the returned aid due to withdraw. We will utilize this information to thoroughly double-check our calculations before issuing official documentation. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388572 (2023-005)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-005 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title ...

2023-005 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary- The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has designed a calendar that displays the attendance days from the first day of school to the last day of school, referring to the school's master calendar. This will be used as a cross-check of days when computing returns. The return calculations were one day off due to the misinterpretation of the semester's ending date. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388571 (2023-004)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Questioned Costs Student Financial Aid Reporting

2023-004 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University used the incorrect value for the total days in the students return to Title IV calculation. In completing the student's withdrawal, the institution used the incorrect amount of aid awarded/ disbursed for the ...

2023-004 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University used the incorrect value for the total days in the students return to Title IV calculation. In completing the student's withdrawal, the institution used the incorrect amount of aid awarded/ disbursed for the applicable period. The university incorrectly calculated the institutional charges within the return to Title IV calculation. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office created a calendar showing days of attendance from the first day of school to the last using the school's master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. Anticipated Completion Date- July 1, 2024

View Audit 300264 Questioned Costs: $1

Finding 388570 (2023-003)

Significant Deficiency 2023

Mid-Atlantc Christian University

NC

Student Financial Aid Reporting Significant Deficiency

2023-003 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University did not correctly report the student's enrollment status to National Student Loan Data System (NSLDS). The Department of Education had a waived window of errors from July 2022 to February 2023. Name and Title...

2023-003 Initial Fiscal Year End, 2023 Summary of Finding- During the audit, the University did not correctly report the student's enrollment status to National Student Loan Data System (NSLDS). The Department of Education had a waived window of errors from July 2022 to February 2023. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University is continuing to improve communication between the Registrar's office, Financial Aid office, National Student Clearinghouse, and NSLDS with the goal of clear and correct reporting to NSLDS. Staff between the different departments have participated in training on enrollment reporting and how National Student Clearinghouse works directly with NSLDS. A monthly check list has also been created to make sure items are getting completed. Anticipated Completion Date- July 1, 2024

View Audit 300264

Finding 388567 (2023-001)

None 2023

Town of Orange

MA

Reporting Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Transportation The Town of Orange, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Transportation The Town of Orange, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF TREASURY COVID-19 Coronavirus State and Local Recovery Funds Federal Assistance Listing Number 21.027 2023-001 – Reporting to the Federal Government Compliance Requirement: Reporting Type of Finding: Compliance and Internal Control over Compliance – Other Matter Criteria or Specific Requirement: Grantees must comply with reporting requirements established by the U.S. Treasury that includes the total grant expenditures incurred for the reporting period. Since the Town is a Non-Entitlement Unit that received less than $10 million in funding, the Town was required to submit a project and expenditure report by April 30, 2022, and annually thereafter. Condition: The electronic report the Town submitted to the U.S. Treasury on April 30, 2023 reported the incorrect amount for total expenditures. Questioned Costs: None Reported. Context: The Town filed the required project and expenditure report in a timely manner. However, while submitting the report the Town entered the incorrect amount for total expenditures. Effect: The expenditures reported on the Town’s project and expenditure report did not match the accounting records. Cause: The Town entered the incorrect amount when submitting the report. Recommendation: Management should correct the report in the next reporting submission. Views of Responsible Officials and Planned Corrective Actions: Management made a good faith effort to correctly report its expenditures to the Treasury Department but made an error while filling out the report. Management will rectify the issue with the next submission in accordance with U.S. Department of Treasury’s recommended guidance. If the Oversight Agency has questions regarding this plan, please call Amber Dupell, Town Accountant at 978-544-1100.

View Audit 300260

Corrective Action Plans

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