Corrective Action Plans

Finding 388562 (2023-010)

Material Weakness 2023

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

Finding 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and one ESSER III report, for a total of five reports. A single employee prepared and submitted...

Finding 2023-010 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and one ESSER III report, for a total of five reports. A single employee prepared and submitted each annual data report without a review or oversight process in place to prevent, or detect and correct, errors. All five reports were selected for testing, two of which were not supported by the School Corporation's records. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start to review the information entered into the required ESSER reports prior to submission and supporting documentation will be retained. Anticipated Completion Date: April 1, 2024

View Audit 300250

Finding 388559 (2023-008)

Material Weakness 2023

Crothersville Community Schools

IN

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness § 200.207 § 200.303

FINDING 2023-008 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Summary of Finding: The School Corporation had not adopted a test security policy. Although training had been provided to staff on an annual basis, the School Co...

FINDING 2023-008 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Summary of Finding: The School Corporation had not adopted a test security policy. Although training had been provided to staff on an annual basis, the School Corporation had not established a system of internal controls to ensure monitoring of Assessment System Security occurred and was adequate. There were no INDIANA STATE BOARD OF ACCOUNTS 40 documented internal controls in place to ensure all individuals that should have received training did receive training. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will implement a Test Security Policy. Currently, the board is on the first reading and the second reading will occur on April 15, 2024. Superintendent is now the Title I director and is keeping the training certifications on file and retained for future audits. Anticipated Completion Date: April 15, 2024

View Audit 300250

Finding 388555 (2023-006)

Material Weakness 2023

Crothersville Community Schools

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: During the audit period the School Corporation submitted three final expenditure reports. The final expenditure reports were completed and submitted by the Treasurer without an oversight or...

FINDING 2023-006 Finding Subject: Title I Grants to Local Educational Agencies - Reporting Summary of Finding: During the audit period the School Corporation submitted three final expenditure reports. The final expenditure reports were completed and submitted by the Treasurer without an oversight or review process in place to prevent, or detect and correct, errors. In addition, the final expenditure report for the Title I School Improvement for program year 2021, due December 30, 2021, was submitted March 7, 2024. Contact Person Responsible for Corrective Action: Terry Richey and Chrystal Street Contact Phone Number and Email Address: 812.793.2061 trichey@crothersville.k12.in.us cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 39 Description of Corrective Action Plan: The corporation treasurer and superintendent will review current internal controls policies especially segregation of duties and the areas in which we are lacking. We will consider rotation of duties in which employees will learn different roles when possible. We will also consider using technological solutions to enhance the reliability and integrity of processes. Another individual will start reviewing the final expenditure reports prior to submission to IDOE. Anticipated Completion Date: April 1, 2024

View Audit 300250

Finding 388547 (2023-001)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

Cheyney University: Additional policies and procedures were implemented to mitigate errors in the future. Pennsylvania Western University: This finding resulted from a combination of staff turnover and the complexity of integration. All grant-related reporting requirements will be reviewed to ensur...

Cheyney University: Additional policies and procedures were implemented to mitigate errors in the future. Pennsylvania Western University: This finding resulted from a combination of staff turnover and the complexity of integration. All grant-related reporting requirements will be reviewed to ensure that they are properly documented and scheduled for completion and review when required by the granting authority.

View Audit 300242

Finding 388538 (2023-004)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will b...

West Chester University: The WCU financial aid team will request the Pell Reconciliation report on COD bi-weekly or weekly basis depending on our disbursements. This report contains Pell awards that have disbursed in our student information system (SIS) and are not recorded at COD. The report will be uploaded into our SIS within 1-2 days. When the report is loaded in our SIS, we will review each file to see which files did not transmit to COD. For the files that fail, we will correct the error/issue in our SIS and send the file out to COD in a timely manner for processing. After our Pell reconciliation is complete, we wll review our SIS and COD to ensure records agree between our SIS and COD (award amounts and processing dates). WCU is currently reviewing its policies and procedures around COD reporting and will ensure students' information is reported timely and accurately between our SIS and COD. WCU understands and agrees that the errors identified in the program review relate to Pell Grant disbursement reporting; and agrees, if a similar error related to Direct Loan disbursement reporting occurred, it could result in skewed interest calculation as students' interest accrues based on the disbursement date reported to COD. Going forward, WCU will review the SIS and COD data to ensure that all booked files link to the appropriate dates between our SIS and COD. Kutztown University: We reviewed our policies and procedures for COD reporting. A financial aid resource has implemented a sweep every fourteen days to ensure that compliance with the 15-day rule for PELL reporting is met consistently.

View Audit 300242

Finding 388537 (2023-003)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure the enrollment effective date, and program enrollment effective date are in alignment between the University system, the National Student Clearinghouse and NSLDS. In the situation where a stude...

East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure the enrollment effective date, and program enrollment effective date are in alignment between the University system, the National Student Clearinghouse and NSLDS. In the situation where a student is withdrawing from the University or being administratively withdrawn due to an unofficial withdrawal, the University Records” Office will monitor student accounts to ensure that adjustments made to student records are not overridden by automated procedures. All reporting will be completed through the National Student Clearinghouse. Kutztown University: We re-evaluated policies and procedures to ensure compliance in reporting. We worked with the Registrar’s Office to rectify any errors in a timely fashion, as well as to detail and update our processes moving forward. A new resource was identified for this responsibility, who is continuously monitoring our submissions to ensure they are accepted in a timely manner. A financial aid resource works in conjunction with the Registrar’s Office to ensure errors are addressed timely to certify the accuracy of our reporting. Cheyney University: Cheyney University of Pennsylvania currently utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to National Student Clearinghouse. The National Student Clearinghouse only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Students did not appear on the rosters, so the National Student Clearinghouse did not provide the enrollment data to NSLDS. Cheyney University learned that NSLDS did not receive students' enrollment status changes from NSC. As of Spring 2023, Cheyney University has implemented procedures to report enrollment status changes and last date of attendance for all Title IV recipients to NSLDS. Beginning August 2024, Cheyney University will begin utilizing BANNER to create the required enrollment file and transmit the information directly to NSLDS vis EdConnect or TDClient. Commonwealth University (Lock Haven): Controls have been put in place across multiple offices to ensure that program enrollment effective date and program enrollment status is reported correctly to NSLDS. Actions will include, but are not limited to, timely review of changes and checking data files prior to upload. West Chester University: Initial action has been taken to update the student's record with NSLDS. WCU will also add an additional check to our transmission process to review the file for this specific scenario. We will develop a report from our student information system to assist us in this review.

View Audit 300242

Finding 388536 (2023-002)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Student Financial Aid Reporting Significant Deficiency § 200.303

West Chester University: We have recently modified our submission schedule to ensure we have adequate time to prepare our files, conduct our pre-submission checks, and resolve errors prior to the monthly exchange of data between the National Student Clearinghouse and NSLDS. We will continue to monit...

West Chester University: We have recently modified our submission schedule to ensure we have adequate time to prepare our files, conduct our pre-submission checks, and resolve errors prior to the monthly exchange of data between the National Student Clearinghouse and NSLDS. We will continue to monitor the time it takes to complete these tasks and make any necessary modifications to support timely reporting to NSLDS. East Stroudsburg University: The University Records’ Office will implement policy and procedures to ensure students’ enrollment statuses are being reported to NSLDS through the National Student Clearinghouse. Reporting will occur on a monthly basis by means of the University Records’ Office transmitting a file to the National Student Clearinghouse. The University Records’s Office will monitor student statuses in NSLDS by randomly sampling students reported through the National Student Clearinghouse to ensure the accuracy of data being reported to NSLDS. Kutztown University: We re-evaluated our reporting procedures and worked with the Registrar’s Office to further redefine our process(es). The Registrar’s Office submits monthly transmissions to NSC (National Student Clearinghouse), who in turn updates our information to NSLDS. A new resource was identified for this responsibility, who is continuously monitoring our submissions to ensure they are accepted in a timely manner. A financial aid resource works in conjunction with the Registrar’s Office to ensure errors are addressed timely to certify the accuracy of our reporting. Cheyney University: Cheyney University of Pennsylvania currently utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to NSC, believing that enrollment would be reported to NSLDS in compliance with federal regulations; unfortunately, NSC only includes enrollment data for students on the enrollment roster they receive from the National Student Loan Data System (NSLDS). Cheyney University is a Heightened Cash Monitoring 2 (HCM2) institution, and students' Title IV aid/disbursements are reported differently than advance pay institutions. Students did not appear on the rosters, so NSC did not provide the enrollment data to NSLDS. While investigating the issues with enrollment reporting for our HCM2 students, Cheyney University learned that NSLDS did not receive students' enrollment from NSC. As of Spring 2023, Cheyney University has implemented procedures to report enrollment for all Title IV recipients to NSLDS. Beginning August 2024, Cheyney University will begin utilizing BANNER to create the required enrollment file and transmit the information directly to NSLDS vis EdConnect or TDClient.

View Audit 300242

Finding 388534 (2023-007)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.502 § 200.510

Cheyney University: The discrepancy in the SEFA is primarily due to a timing issue with the approval of the HCM2 Claims. However, the Federal Title IV grant and loan funds should be properly reflected in the upcoming SEFA because the University will be current in its processing of 2023-2024 Federal ...

Cheyney University: The discrepancy in the SEFA is primarily due to a timing issue with the approval of the HCM2 Claims. However, the Federal Title IV grant and loan funds should be properly reflected in the upcoming SEFA because the University will be current in its processing of 2023-2024 Federal Student Aid and request for reimbursement. Hence, the University should not have this issue in the FY24 fiscal year. In addition to timely processing, relevant staff in the Financial Aid, Bursar, and Business Office have participated in Federal Student Aid (FSA) Cash Management Training. Furthermore, effective July 2023, reconciliation has been outsourced to FAS. Therefore, monthly reconciliations will inform the SEFA development process. Meaning, adjustments that required for the SEFA will be made more timely than in the recent past.

View Audit 300242

Finding 388533 (2023-006)

Significant Deficiency 2023

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

Pennsylvania Western University: This finding resulted from reporting issues caused by the complexity of integration. These reporting issues have been corrected and now accurately identify students who need to be reviewed for official and unofficial withdrawals. Cheyney University: In July 2023, Ch...

Pennsylvania Western University: This finding resulted from reporting issues caused by the complexity of integration. These reporting issues have been corrected and now accurately identify students who need to be reviewed for official and unofficial withdrawals. Cheyney University: In July 2023, Cheyney University signed an agreement with Financial Aid Services, LLC (FAS) to outsource many of the financial aid related functions. Return to Title IV (R2T4) was one of the functions outsourced. The process to begin outsourcing was started in December 2023. In addition to outsourcing R2T4, the Office of the Registrar will provide the Office of Student Financial Services (SFS) with a list of students who are not registered for each semester. This distribution will culminate with census reporting to PASSHE and allow SFS to notify about repayment and Return to Title IV processes. For students who apply for graduation for a particular semester, a distribution of names, identification numbers, and anticipated graduation semester, will be provided to SFS so that they can complete their exit counseling procedures.

View Audit 300242

Finding 388531 (2023-001)

Significant Deficiency 2023

Cornerstone Montgomery, Inc.

MD

Allowable Costs / Cost Principles Reporting Significant Deficiency

COVID 19 - Demonstration Programs to Improve Community Mental Health Services 93.829 Recommendation: We recommend internal controls over reporting be enhanced to ensure evidence is maintained to support the reports and review performed over the reports. Explanation of disagreement with audit findi...

COVID 19 - Demonstration Programs to Improve Community Mental Health Services 93.829 Recommendation: We recommend internal controls over reporting be enhanced to ensure evidence is maintained to support the reports and review performed over the reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We are in the process of re-evaluating the reporting process to ensure documentation is maintained to support the reporting requirements. Name of the contact person responsible for corrective action: Lisa Katz, Chief Program Officer Planned completion date for corrective action plan: Currently underway and planned to be completed by June 30, 2024.

View Audit 300238

Finding 388530 (2023-005)

Material Weakness 2023

City of Jackson, Tennessee

TN

Procurement, Suspension & Debarment Reporting Internal Control / Segregation of Duties

We will ensure future reports include all previously omitted expenditures and work to implement controls sufficient to reconcile the programatic reporting to the general ledger on a quarterly basis.

View Audit 300234

Finding 388529 (2023-001)

Material Weakness 2023

Consolidated North County Levee District

MO

Material Weakness Reporting Internal Control / Segregation of Duties

2023-001 Material Weakness in Internal Control over financial reporting Criteria: Management is responsible for establishing and maintaining internal controls in the financial reporting system and for the fair presentation of the financial position, results of operations, and disclosures in th...

2023-001 Material Weakness in Internal Control over financial reporting Criteria: Management is responsible for establishing and maintaining internal controls in the financial reporting system and for the fair presentation of the financial position, results of operations, and disclosures in the financial statements, in conformity with the cash basis of accounting. Condition: The District does not have an individual that has the ability to evaluate the completeness and accuracy of the statements presented in accordance with the cash basis of accounting. Cause: The District only has a volunteer board and has elected to outsource the preparation of the annual financial statements. Effect: The District must rely on its external auditors to determine adherence to applicable cash basis of accounting. CORRECTIVE ACTION PLAN RESPONSE: Management concurs with this finding and will continue to evaluate the risk of outsourcing financial statement preparation versus the cost of staffing at this level. Anticipated completion date: 6/30/24 Responsible party: Kevin Machens, President Please contact Kevin Machens at 314-750-2519 with questions regarding this plan.

View Audit 300231

Finding 388520 (2023-004)

Significant Deficiency 2023

City of Richmond

VA

Reporting Subrecipient Monitoring Significant Deficiency § 200.303

Recommendation: We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements. Explanation of disagreement ...

Recommendation: We recommend that the Department develop internal controls and procedures to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance in accordance with FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: HCD has made it part of a dedicated staff member to input the data into the FSRS system on a timely basis. HCD will also update their process so that all applicants must provide their UEI number. Name(s) of the contact person(s) responsible for corrective action: Sherrill Hampton Planned completion date for corrective action plan: 7/31/24

View Audit 300220

Finding 388512 (2023-003)

Significant Deficiency 2023

Dupage Housing Authority

IL

Allowable Costs / Cost Principles HUD Housing Programs Reporting

Finding 2023-003: Overpayments to Landlords (Significant Deficiency) Corrective Action Plan: DHA Management has worked with our financial institution to ensure that the positive pay function is working and duplicate payments will not be posted to Landlord accounts. Name of Responsible Person: Cheron...

Finding 2023-003: Overpayments to Landlords (Significant Deficiency) Corrective Action Plan: DHA Management has worked with our financial institution to ensure that the positive pay function is working and duplicate payments will not be posted to Landlord accounts. Name of Responsible Person: Cheron Corbett Completion Date: July 31, 2023

View Audit 300217

Finding 388511 (2023-002)

Significant Deficiency 2023

Dupage Housing Authority

IL

HUD Housing Programs Internal Control / Segregation of Duties Reporting

Finding 2023-002: Late Submission of Unaudited Data to REAC (Significant Deficiency) Corrective Action Plan: Due to the abrupt quitting of our previous Comptroller cause a delay in the submission of our unaudited financials. DHA has hired a new Comptroller and we have monthly meetings to ensure that...

Finding 2023-002: Late Submission of Unaudited Data to REAC (Significant Deficiency) Corrective Action Plan: Due to the abrupt quitting of our previous Comptroller cause a delay in the submission of our unaudited financials. DHA has hired a new Comptroller and we have monthly meetings to ensure that all accounting data is being recorded timely. This will allow us to submit timely financials to HUD. . Name of Responsible Person: Cheron Corbett, Executive Director Projected Completion Date: December 31, 2024

View Audit 300217

Finding 388487 (2023-002)

Significant Deficiency 2023

Roselle Public Schools

NJ

Reporting

All grant expenditure reports submitted will be reconciled with the District's reporting system to ensure accuracy of submission. The District will seek advise on how to restore the expended carryover amount.

View Audit 300214

Finding 388478 (2023-002)

Significant Deficiency 2023

Town of Middlebury, Vermont

VT

Internal Control / Segregation of Duties Reporting Special Tests & Provisions

Recommendation: To correct these deficiencies, management would need to hire personnel with adequate accounting experience to perform these functions. The Town would need to weigh the costs of these corrections verse the benefit.

View Audit 300206

Finding 388475 (2023-001)

None 2023

Universidad Central Del Caribe, Inc.

PR

Student Financial Aid Eligibility Reporting

To correct the student reporting process in NSLDS and in addition to the actions already implemented, the following actions will be executed: 1. By June 30, 2024, achieve 100 % accurate reporting by performing a bi-monthly internal reconciliation (July, September, November, January, March, May): a. ...

To correct the student reporting process in NSLDS and in addition to the actions already implemented, the following actions will be executed: 1. By June 30, 2024, achieve 100 % accurate reporting by performing a bi-monthly internal reconciliation (July, September, November, January, March, May): a. Bi-monthly the first day of the month of the reporting period, the IEO and Registrar offices will prepare the Enrollment Changes List (ECL). The list will include withdrawals, LOA, graduations, and other enrollment status changes. The ECL will be conciliated with each academic program leader within 24 hours. b. 2 calendar days after (a), the Registrar will certify and sign the list to assure the enrollment status is accurate. c. 3 calendar days after (b), the Registrar Office and IEO will do the data entry in the NSLDS platform. d. 1 calendar days after (c), the reconciled Enrollment Changes List will be revised by the Assistant Dean of Licensing and Accreditation for validation. e. 2 days calendar after (d), the reconciled and validated ECL be revised by Academic Dean and Vice-President for certification of the accurate NSLDS reporting. 2. By June 30, 2024, achieve 100 % of accurate reporting to the NSLDS by continuing the implementation of the monthly process of reconciliation of withdrawals and verification of attendance in the SharePoint. 3. By June 30, 2024, assure quality improvement through re-training of all Registrar Office staff and academic programs leadership in the processes and responsibilities regarding compliance reporting of student status in NSLDS and our internal policies and procedures.

View Audit 300200

Finding 388467 (2023-003)

Significant Deficiency 2023

Saint Elizabeth University

NJ

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

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates...

Common Origination and Disbursement (COD) Reporting Planned Corrective Action: The University’s Financial Aid Office will update the anticipated disbursement date to reflect the actual disbursement for 2022-23. We will review the current award year to ensure that the anticipated disbursement dates reflect the actual disbursement date. Person Responsible for Corrective Action Plan: Nicholas Capodice, Director of Financial Aid Anticipated Date of Completion: April 30, 2024

View Audit 300191

Finding 388461 (2023-002)

Significant Deficiency 2023

Brooklyn Law School

NY

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the ...

2023-002 Enrollment Reporting – Significant Deficiency United States Department of Education— ALN 84.268 Federal Direct Student Loans Program Criteria: Per CFR §658.309, unless it expects to submit its next updated enrollment report to the Secretary within the next 60 days, a school must notify the Secretary within 30 days after the date the school discovers that: (i) a loan under title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the school, and the student has ceased to be enrolled on at least a half-time basis or failed to enroll on at least a half-time basis for the period for which the loan was intended; or (ii) a student who is enrolled at the school and who received a loan under title IV of the Act has changed his or her permanent address. Condition: For one out of 25 students sampled, the effective date reported in NSLDS was incorrect. For four out of 25 students sampled, the status change was not reported in NSLDS in the next enrollment report or within 30 days of the date of determination. Cause: The Law School does not have a formalized policy to address enrollment reporting for summer terms. Effect: Enrollment reporting was inaccurate. Federal loan servicers utilize this information to determine the appropriate status for repayment terms and as such, had incorrect information. Enrollment reporting was not submitted within the required time frame. Questioned Costs: None. Context: See condition above. Recommendation: We recommend the Law School enhance their procedures and formalize a written policy for all terms of enrollment reporting. Corrective Actions Taken: Julie Brown, the Registrar will be given access to the NSLDS database to verify the information submitted through the National Student Clearinghouse is reported completely and accurately, particularly in relation to enrollment statuses that change during the non-required summer terms. This is part of an ongoing process as this information is updated multiple times per year. The Registrars Office will also draft a policy including timelines for uploading information to the National Student Clearinghouse and dates for verification of information in NSLDS. Responsible party: Julie Brown, Registrar. 718-780-7918 julie.brown@brooklaw.edu

View Audit 300177

Finding 388456 (2023-003)

Significant Deficiency 2023

Colorado Mountain College

CO

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

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.068 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes ...

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.068 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend that the College work with their third-party servicer and implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS are reported accurately and timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Registrar and Financial Aid departments have established a set schedule for enrollment reporting to the National Student Clearinghouse (NSC) and National Student Loan Database System (NSLDS) to ensure accurate and timely reporting happens each month and graduate reporting at the end of semester, within the 60-day window. To ensure CMC meets requirements to report all changes to enrollment and continuing enrollment within the 60-days, the monthly enrollment will follow best practice to submit every 30 days to allow time for correction of any errors prior to submission to NSLDS. The Student Affairs Systems Specialist will pull the enrollment report from CMC’s Student Information System (SIS) on the 19th for submission to NSC on the 20th of each month. If the 20th falls on the weekend it will be the Friday before. The Student Affairs Systems Specialist will correct any enrollment errors with NSC within 3 business days from the time of submission. The enrollment submission from NSC to NSLDS is scheduled for the 3rd of each month, and the Assistant Director of Financial Aid will pull a list from CMC’s SIS to match with NSLDS on the 15th of each month. If the 15th falls on the weekend it will be the Friday before. If there are any enrollment errors or missing students in NSLDS the Assistant Director of Financial Aid will notify the Student Affairs Systems Specialist to update student enrollment data within NSLDS. If there are no errors or missing enrollments in NSLDS, the Assistant Director of Financial Aid will send an email to the Student Affairs Systems Specialist to confirm the report is accurate and submitted. The graduate report will be submitted to NSC by the Student Affairs Systems Specialist on the second Friday after the end of the semester to allow for grade and graduation processing. The Assistant Director of Financial Aid will verify the graduate report within NSLDS two weeks after submission to NSC and email confirmation or request corrections with the Student Affairs Systems Specialist. Name(s) of the contact person(s) responsible for corrective action: Natalie Torres and Janelle Cook Planned completion date for corrective action plan: May 2024

View Audit 300168

Finding 388443 (2023-014)

Significant Deficiency 2023

State of Hawaii, Department of Accounting and General Services

HI

Subrecipient Monitoring Reporting Significant Deficiency

2023‐014 – Reporting (Significant Deficiency) State Department of Defense AL Number: 97.067 Program Title: Homeland Security Grant Program Condition The auditing firm selected three subawards that were executed between July 1, 2022 – June 30, 2023, noting that FFATA reports for the selected subaward...

2023‐014 – Reporting (Significant Deficiency) State Department of Defense AL Number: 97.067 Program Title: Homeland Security Grant Program Condition The auditing firm selected three subawards that were executed between July 1, 2022 – June 30, 2023, noting that FFATA reports for the selected subawards were not filed timely. Current Status of Corrective Action Plan Concur. It is our commitment to address this issue promptly and implement necessary measures to prevent its recurrence. We understand the importance of accurate and timely data entry in the FFATA portal for federal awards and sub awards. In response to this issue, we have developed a corrective action plan to address the root causes and prevent similar occurrences in the future: -Review of Process: We will conduct a thorough review of our current process for entering funding amounts into the FFATA portal to identify any inefficiencies or gaps in the process. -Training and Awareness: We will provide additional training to other personnel in the grant section to ensure that there is continuity in the tasks. This will include reinforcing the importance of adhering to established deadlines and protocols. -Implement Reminders: We will implement automated reminders and notifications to alert grant staff members via shared Microsoft Outlook Calendar of impending deadlines for entering new federal award into the FFATA portal. These reminders will serve as a proactive measure to prevent delays and ensure timely completion of tasks. Lastly, reminder indicators such as; receiving the official grant award and executing a memorandum of agreement with sub recipients will be an indicator for action to process FFATA reporting. The FFATA information and process already exists in our Homeland Security Procedural Manual (Page 49) that we maintain annually. We will continue to maintain and make any necessary revisions if there are any changes. Person Responsible Glen Badua, Grants Manager Anticipated Date of Completion February 20, 2024

View Audit 300162

Finding 388437 (2023-012)

Material Weakness 2023

State of Hawaii, Department of Accounting and General Services

HI

Subrecipient Monitoring Material Weakness Reporting

2023‐012 – Reporting (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition Reporting required by Section 2, Full Disclosure...

2023‐012 – Reporting (Material Weakness) State Department of Labor and Industrial Relations AL Numbers and Program Title: 17.258 – WIOA Adult Program 17.259 – WIOA Youth Activities 17.278 – WIOA Dislocated Worker Formula Grant (WIOA Cluster) Condition Reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of the FFATA was not completed. Current Status of Corrective Action Plan Concur. -Due to changes in program personnel, there was miscommunication between the parties responsible for filing the FFATA reports. -Previous ASO left abruptly in 2023 with limited to no cross‐training. Other positions vacated in 2023 as well. The ASO and Accountant VI vacancies were filled on December 1, 2023 and February 1, 2024, respectively. -The ASO will come up with a checklist of pertinent reports that are due for WIOA programs including FFTA reporting and have the responsible staffs (Accountant and Supervisor) report to ASO Officer and WDD Administrator monthly for verification. Person Responsible Lynn Araki‐Regan, Administrative Services Officer Anticipated Date of Completion March 15, 2024

View Audit 300162

Finding 388427 (2023-006)

Significant Deficiency 2023

State of Hawaii, Department of Accounting and General Services

HI

Subrecipient Monitoring Reporting Significant Deficiency

Finding No. 2023‐006 – Reporting (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.615 Program Title: Cooperative Endangered Species Conservation Fund Condition A prime recipient of a federal award is required to file a Federal Funding Accountability and Transpar...

Finding No. 2023‐006 – Reporting (Significant Deficiency) State Department of Land and Natural Resources AL Number: 15.615 Program Title: Cooperative Endangered Species Conservation Fund Condition A prime recipient of a federal award is required to file a Federal Funding Accountability and Transparency Act (FFATA) report to the FFATA Subaward Reporting System (FSRS) by a specific period for any subaward greater than or equal to $30,000. The auditing firm haphazardly tested the one subaward executed in FY 2023 and noted FFATA report was not completed timely. Current Status of Corrective Action Plan Concur. DLNR has procedures in place for the submission of FFATA reports and will ensure that the reports are filed timely. Person Responsible Cynthia C. Gomez, Fiscal Management Officer Anticipated Date of Completion Completed.

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Finding 388415 (2023-102)

Material Weakness 2023

Santa Cruz County

AZ

Reporting Subrecipient Monitoring Cash Management § 200.303

Assistance Listings number and program name: 97.067 Homeland Security Grant Program Contact Person(s): Augustin Huerta Jr., Commander Anticipated completion date: April 30, 2024 Due to unexpected staff turnover, including the retirement of the office manager responsible for submitting H...

Assistance Listings number and program name: 97.067 Homeland Security Grant Program Contact Person(s): Augustin Huerta Jr., Commander Anticipated completion date: April 30, 2024 Due to unexpected staff turnover, including the retirement of the office manager responsible for submitting Homeland Security Grant Program quarterly reports, the Sheriff’s Office ultimately relied on staff that was not properly trained nor have sufficient time to prepare the reports. The Sheriff’s Office has since improved the understanding of grant administration and submission process. The Sheriff's Office is working collaboratively to ensure accurate and timely submission of required documents to the grantor. Subsequent to June 30, 2023, the Sheriff's Office implemented calendar reminders of deadlines, statistic and financial reports are generated one week in advance of the due date, and quarterly reports are completed by the 13th day of each month. The Sheriff's Office will work with County finance staff to develop and implement written policies and procedures.

View Audit 300146

Corrective Action Plans

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