Corrective Action Plans

Finding 369739 (2023-001)

Significant Deficiency 2023

Loras College

IA

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

Corrective Action: Management has reviewed policies and procedures for accurate reporting of enrollment status and changes to be in compliance with federal regulations. The College will designate a secondary responsible individual to conduct a review of the preparation of the digital file and review...

Corrective Action: Management has reviewed policies and procedures for accurate reporting of enrollment status and changes to be in compliance with federal regulations. The College will designate a secondary responsible individual to conduct a review of the preparation of the digital file and review the digital file of student enrollment changes before it is submitted to the National Student Loan Clearinghouse. The Office of Financial Planning will conduct monthly review as a secondary review of enrollment reporting in the National Student Loan Data System (NSLDS).

View Audit 291202

Finding 369714 (2023-003)

Material Weakness 2023

Springs Valley Community Schools Corporation

IN

Questioned Costs School Nutrition Programs Internal Control / Segregation of Duties § 200.303

Finding 2023-003 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corp...

Finding 2023-003 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Felicia Wolfington/Sasha Robison Contact Phone Number: (812) 936-4474 x232 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of the reporting to ensure they are meeting the grant agreement and cash management compliance requirements. Anticipated Completion Date: 02/16/2024

View Audit 291176 Questioned Costs: $1

Finding 369696 (2023-001)

Material Weakness 2023

United Way of Central Virginia, Inc.

VA

Internal Control / Segregation of Duties Reporting

Management agres with the auditor's recommendation, and the following action will be taken to improve the situation. In conscientious recognition of these challenges, the newly appointed CEO, who assumed leadership in 2023, has undertaken a comprehensive approach to rectify and fortify organizationa...

Management agres with the auditor's recommendation, and the following action will be taken to improve the situation. In conscientious recognition of these challenges, the newly appointed CEO, who assumed leadership in 2023, has undertaken a comprehensive approach to rectify and fortify organizational processes. A structured framework, incorporating checks and balances, has been implemented. This framework mandates monthly reporting directly to the CEO, treasurer, and board. This restructuring aims to fortify our organizational resilience and ensure adherence to best practices. Management reassures our commitment to a progressive and responsible trajectory, leadership is unwaveringly confident that, with the ongoing training initiatives, installation of best practices, and stringent accountability requirements, segregation of duties will be established.

View Audit 291157

Finding 369694 (2023-001)

Material Weakness 2023

Thaddeus Stevens College of Technology

PA

Reporting

Management will put a process in place to review and monitor changes in HEERF reporting requirements. As part of this revised process, all data will be subject to final review prior to submission of any HEERF information to ensure accuracy and consistency.

View Audit 291155

Finding 369685 (2023-001)

Significant Deficiency 2023

Family Guidance Center of Alabama, Inc.

AL

Reporting

Corrective action plan: The 2022 and 2023 reports will be prepared and submitted as soon as possible. The reporting dates and processes will be documented to ensure timely submission in future. Individual(s) Responsible: Debbie Pinnock ...

Corrective action plan: The 2022 and 2023 reports will be prepared and submitted as soon as possible. The reporting dates and processes will be documented to ensure timely submission in future. Individual(s) Responsible: Debbie Pinnock Completion date: Plan has been implemented as of date of audit submission.

View Audit 291117

Finding 369683 (2023-001)

Significant Deficiency 2023

Cccs Farm Labor Housing Corporation

CO

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Views Responsible Officials and Planned Corrective Actions: We concur with the observations and recommendations as placed forth by our auditors – KCM. We experienced personnel related issues and did not adequately have bench strength in place to compensate. To address: 1. We will file the outstandi...

Views Responsible Officials and Planned Corrective Actions: We concur with the observations and recommendations as placed forth by our auditors – KCM. We experienced personnel related issues and did not adequately have bench strength in place to compensate. To address: 1. We will file the outstanding reports. 2. Have initiated a review and update of a ministry-wide master deliverables schedule to ensure compliance with timely filings. 3. Will ensure multiple team members are familiar with and capable of completing the filing.

View Audit 291102

Finding 369661 (2023-001)

Significant Deficiency 2023

Carroll Community College

MD

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

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 a student’s correct enrollment status and effective date was not reported to NSLDS. Recomme...

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 a student’s correct enrollment status and effective date was not 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. Action taken in response to finding: The College agrees with the recommendation to evaluate the procedures and policies related to reporting status changes to the Department of Education’s National Student Loan Data System (NSLDS). For many years, Carroll has contracted with the National Student Clearinghouse (NSC) for their comprehensive enrollment and graduate reporting services. They become an authorized agent, providing status updates to the NSLDS on our behalf. Carroll has begun a review, using the NSC and their resources and tools, to better understand why the student’s graduate status was not transmitted from the NSC to the NSLDS. Carroll staff will review the resources to ensure our procedures and processes meet the NSC expectations. Additionally, at the end of each term, the College will randomly select three students with status changes to verify that the reporting process to the NSLDS is accurate and timely. Name(s) of the contact person(s) responsible for corrective action: Mr. Gregg Bricca, Director of Institutional Effectiveness. Planned completion date for corrective action plan: 6/30/24

View Audit 291047

Finding 369632 (2023-001)

Significant Deficiency 2023

Wayside House, Inc.

FL

Reporting Internal Control / Segregation of Duties

Management Response: The Organization will continue to strengthen our internal controls by having the employees complete the required Time and Effort certifications monthly or semiannually with further review and approval by the respective Department Heads. The employees will certify their monthly p...

Management Response: The Organization will continue to strengthen our internal controls by having the employees complete the required Time and Effort certifications monthly or semiannually with further review and approval by the respective Department Heads. The employees will certify their monthly personnel activity reports indicating actual time spent working on multiple activities or cost objectives, while employees who worked on a single cost objective will submit semi‐annual Time and Effort certifications reviewed and approved by their Department Heads.

View Audit 291011

Finding 369589 (2023-003)

Significant Deficiency 2023

Arizona Christian University

AZ

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disa...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the Institute review its reporting procedures to ensure that students’ statuses are 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: After an analysis of the auditor's finding, ACU's director of financial aid, AVP of institutional effectiveness, and associate director of institutional research concluded that a misunderstanding of the National Clearinghouse's process for summer enrollment reporting was the cause of the finding. During the summer months of June, July, and August, ACU has been submitting enrollment reports, including withdrawals, only for students enrolled in summer terms. Withdrawals of students enrolled in the spring term were not being reported until after the fall term commenced. To remedy this finding, the Department of Financial Aid (FA) and the Office of Institutional Effectiveness (OIE) has coordinated with the National Student Clearinghouse (NSC) to identify which reporting method would ensure that all withdrawn students are accounted for and reported between the spring and fall terms. It was determined we would send custom files that include all withdrawn students in early June and July. The report will be uploaded through the NSC's secure file upload system at least once between May 30th and August 30th, with no more than 60 days between any two enrollment file submissions. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Jeff Phillips and Eric Tompkins Planned completion date for corrective action plan: May/June 2024

View Audit 290967

Finding 369584 (2023-002)

Significant Deficiency 2023

Arizona Christian University

AZ

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit fi...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The incorrect date was for a student who received the Pell Grant. When we batch Pell student awards in COD; and return funds at the same time, this will often cause a shortage in our Pell G5 account. This will delay the disbursement date on the school side. Although COD releases the disbursement, the funds are not available in G5 until days later and in some cases weeks later. The first step is to not process returns and draw downs at the same time. This will ensure the funds are in the Pell G5 acount so disbursment dates will match. The second piece is to audit the disbursement dates at the end of each semester to ensure we match. Name(s) of the contact person(s) responsible for corrective action: Lisa Stone, Joyce Hatch and Kelly Reyes Planned completion date for corrective action plan: November 2023

View Audit 290967

Finding 369581 (2023-001)

Significant Deficiency 2023

City of Columbia, Missouri

MO

Reporting Significant Deficiency Internal Control / Segregation of Duties

The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirement and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting ...

The Department of Public Health and Human Services (PHHS) will create the proper processes and procedures to track reporting requirement and document internal review and approvals prior to report submissions. The Grant Administrator will create the proper processes and procedures to track reporting requirements and notify departments of upcoming submission deadlines.

View Audit 290965

Finding 369576 (2023-003)

Significant Deficiency 2023

Arc Knox County

TN

Reporting Internal Control / Segregation of Duties

Accounting responsibilities between accounting staff are being evaluated and will be reassigned to include bank reconciliation responsibilities and any accounting functions regarding recording & reporting of federal awards. All changes in accounting responsibilities will be reassigned and implemente...

Accounting responsibilities between accounting staff are being evaluated and will be reassigned to include bank reconciliation responsibilities and any accounting functions regarding recording & reporting of federal awards. All changes in accounting responsibilities will be reassigned and implemented by the end of fiscal year 2023-2024.

View Audit 290951

Finding 369514 (2023-004)

Significant Deficiency 2023

Rapid City Club for Boys, Inc.

SD

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Reporting

Finding No 2023-004: Uniform Guidance Written Policies Responsible Individuals: Roni Williamson, Controller Corrective Action Plan: The Organization will adopt required Uniform Guidance policies. Anticipated Completion Date: May 31, 2024

View Audit 290783

Finding 369512 (2023-001)

Material Weakness 2023

Rapid City Club for Boys, Inc.

SD

Reporting

Finding No 2023-001: Financial Statement and SEFA Preparation Responsible Individuals: Roni Williamson, Controller Corrective Action Plan: The Organization has accepted the risk associated with the finding regarding the preparation of the combined financial statements and will continue to have the i...

Finding No 2023-001: Financial Statement and SEFA Preparation Responsible Individuals: Roni Williamson, Controller Corrective Action Plan: The Organization has accepted the risk associated with the finding regarding the preparation of the combined financial statements and will continue to have the independent auditor prepare the annual consolidated financial statements. Anticipated Completion Date: Ongoing

View Audit 290783

Finding 369497 (2023-003)

Significant Deficiency 2023

City of Edmond

OK

Reporting

Identifying number: 2023-003 Significant Deficiency Coronavirus State and Local Fiscal Recovery Funds Finding: Procedures had not been fully established to ensure accurate quarterly reporting of costs and obligations incurred. Action taken or planned: Reporting of the quarterly ARPA submissions is ...

Identifying number: 2023-003 Significant Deficiency Coronavirus State and Local Fiscal Recovery Funds Finding: Procedures had not been fully established to ensure accurate quarterly reporting of costs and obligations incurred. Action taken or planned: Reporting of the quarterly ARPA submissions is based on recorded transactions as of the due date of the quarterly report. The finance software posts invoices based on the invoice date rather than posting when the invoice is paid. Upon reconciliation of the difference noted above, it was discovered that invoices that were dated as of a particular quarter were paid and recorded well after the due date of the quarterly ARPA submission so could not be included in the quarterly report. Moving forward, we will reconcile to reflect only what is actually paid in time to be included in the ARPA submission so our internal records agree to the submission. We will not report to ARPA any funds that have not been expended because circumstances such as pricing, abandonment of a project, etc. can change before payment and if these items are reported before paid, it would cause erroneous reporting of ARPA funds. Any questions regarding this plan should be directed to Kathy Panas, Finance Director at 405.359.4521.

View Audit 290770

Finding 369472 (2023-002)

Significant Deficiency 2023

Western Seminary

OR

Questioned Costs Student Financial Aid Reporting

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to trac...

Untimely Returns of Title IV Funds (R2T4) Planned Corrective Action: We agree with this recommendation. We continue strengthening the tracking system around the timely processing of R2T4 refunds. From the Fall 2023 semester, we developed a report within our Student Information System (SIS) to track students who both received a loan and have dropped classes within Western Seminary’s SIS. From the Spring 2024 semester, we require attendance to be tracked in all classes, including in-person classes. We historically already track attendance of online courses. Financial Aid and the Business Office will have access to regularly scheduled reports to quickly identify when students stop attending class to determine whether an R2T4 form is required and should be processed. Person Responsible for Corrective Action Plan: Jonathan Gibson, CFO Anticipated Date of Completion: June 30, 2024

View Audit 290692 Questioned Costs: $1

Finding 369459 (2023-001)

Significant Deficiency 2023

Susquehanna Workforce Network INC

MD

Allowable Costs / Cost Principles Reporting

Names of Contact Persons: Kimberly Justus, Executive Director, Julie Brown, Fiscal and HR Manager Corrective Action Plan: We are in agreement with the finding and will ensure future submissions are completed timely. We completed the submission as soon as the requisite information was available in J...

Names of Contact Persons: Kimberly Justus, Executive Director, Julie Brown, Fiscal and HR Manager Corrective Action Plan: We are in agreement with the finding and will ensure future submissions are completed timely. We completed the submission as soon as the requisite information was available in July 2023. Expected Completion Date: See corrective action plan, all findings have been resolved.

View Audit 290661

Finding 369446 (2023-001)

Material Weakness 2023

Lapeer Community Schools of Lapeer County

MI

Internal Control / Segregation of Duties Material Weakness Reporting

Condition: Final Expenditure Reports due on November 29, 2022 for the ESSER II Section 23b Credit Recovery grant and the ESSER II Section 23b Before/After School grant were submitted on September 11, 2023. Planned Corrective Action: Finding has been corrected. Upon discovery of the oversight, the Fi...

Condition: Final Expenditure Reports due on November 29, 2022 for the ESSER II Section 23b Credit Recovery grant and the ESSER II Section 23b Before/After School grant were submitted on September 11, 2023. Planned Corrective Action: Finding has been corrected. Upon discovery of the oversight, the Final Expenditure Reports were reopened and completed on September 11, 2023. Further, the District acknowledges the lack of timeliness of submitting the Final Expenditure Reports, and has implemented procedures to ensure all reporting surrounding final expenditures is completed and submitted to granting authority in accordance with terms of the agreement going forward. Contact person responsible for corrective action: Erica Ingles, Finance Director and Jennifer Mudge, Supervisor of School Improvement and Grant Programs Anticipated Completion Date: 9/11/2023

View Audit 290639

Finding 369432 (2023-007)

None 2023

Newberry College

SC

Student Financial Aid Reporting Eligibility

Enrollment Reporting to NSLDS Planned Corrective Action: We have created a process with specific individuals responsible for updating and submitting the roster timely; train staff and create and follow policies and procedures to ensure no delays in reporting a change in status. We have designated...

Enrollment Reporting to NSLDS Planned Corrective Action: We have created a process with specific individuals responsible for updating and submitting the roster timely; train staff and create and follow policies and procedures to ensure no delays in reporting a change in status. We have designated an individual to pull a statistical report from NSLDS to verify the reporting is updated for each period of enrollment. Person Responsible for Corrective Action Plan: Marilyn Eason, Registrar Anticipated Date of Completion: This problem should be resolved when Newberry moves to the J1 platform this spring. It is expected enrollment reporting will be automated by the summer of 2024.

View Audit 290607

Finding 369363 (2023-003)

Material Weakness 2023

Oklahoma Panhandle State University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness § 200.303

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Universi...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ellucian, the producer of Banner, had a known defect that caused incorrect status change dates to be inserted in the Banner program which processes student enrollments. This defect was not known to me at the time, therefore, it was not something I was aware to be looking for when completing enrollment reporting. There were no errors which would have alerted me to the issue. See case PB006205. Known defect now seems to be corrected. Will review current processes in order to ensure the continuance of timely and accurate reporting, and to eliminate the possibility of future errors being at the fault of the University. Name(s) of the contact person(s) responsible for corrective action: Erin Moore and Dasha Smith Planned completion date for corrective action plan: 4/1/24

View Audit 290586

Finding 369359 (2023-002)

Significant Deficiency 2023

Oklahoma Panhandle State University

OK

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

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the Universi...

Federal Supplemental Educational Opportunity Grant - Assistance List No. 84.007 Federal Work Study Program- Assistance Listing No. 84.033 Federal Pell Grant Program - Assistance Listing No. 84.063 Federal Direct Student Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University review reporting processes to ensure all students that require exit counseling receive it in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Request a formal count of all graduates from Registrar at the end of each semester and review the number of exit counseling notifications sent from financial aid to ensure notifications are sent to all appropriate graduating students. Update procedures to reflect additional review. Name(s) of the contact person(s) responsible for corrective action: Dasha Smith Planned completion date for corrective action plan: 4/1/24

View Audit 290586

Finding 369346 (2023-004)

Material Weakness 2023

Drug Prevention Resource Center D/b/a Inneract Alliance

FL

Material Weakness Reporting Internal Control / Segregation of Duties

Timely Reporting Condition: There was a lack of evidence of timely remittance of two PPG reports. There was also one instance of board listing report not submitted by required due date. Recommendation: We recommend documenting and retaining all submittal support when reports are submitted each year....

Timely Reporting Condition: There was a lack of evidence of timely remittance of two PPG reports. There was also one instance of board listing report not submitted by required due date. Recommendation: We recommend documenting and retaining all submittal support when reports are submitted each year. CLA also recommends that the Center keep track of relevant due dates to insure timely submittal of reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: PPG reports were submitted on time whenever possible however there were instances where changes were requested and there were subsequent reports which made the submission date appear to be tardy. For future clarification, the staff will add date submitted on the bottom of those reports to be saved in our own database with additional dates for 2nd or 3rd submissions due to change requests. Name(s) of the contact person(s) responsible for corrective action: Angie Ellison Planned completion date for corrective action plan: Staff will add date submitted to the Quarterly reports already submitted for the 23/24 year and will include the submittal date to all future quarterly reports for ppg and all reports requested by managing entity. If the Oversight Agency has question"s regarding this plan, please call Angie Ellison at (863) 802-0777 .

View Audit 290570

Finding 369345 (2023-003)

Material Weakness 2023

Drug Prevention Resource Center D/b/a Inneract Alliance

FL

Material Weakness Reporting Matching / Level of Effort / Earmarking

Matching Calculation Condition: During review of yearly match calculation report, It was noted the match was not correctly reported. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing match form. Expla...

Matching Calculation Condition: During review of yearly match calculation report, It was noted the match was not correctly reported. Recommendation: We recommend documenting via an approval form with written or electronic signatures designating who is preparing and who is reviewing match form. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Match reports are input into a data document that includes providers in 14 counties. For this reason, our managing entity was requested to send our version without the other counties. The wrong version was sent (quarter 3 instead of final year end version) therefore from this date forward we will keep each quarterly version in our database with added line items that list the preparer and tile approval w/date. Name(s) of the contact person(s) responsible for corrective action: Angie Ellison Immediate: Staff will go back to quarter 1 of 23/24 year and make these changes with copies in database as well as preparer and approval lines w/date. These documents will be prepared in this fashion from this date forward.

View Audit 290570

Finding 369334 (2023-003)

None 2023

Clinton Community School District

WI

Questioned Costs School Nutrition Programs Allowable Costs / Cost Principles

The District will update the annual calculation to include a comparison of the base used for the indirect cost adjustment. Upon identification of the overcharge, the District posted a correcting entry to reduce the indirect costs of the program.

View Audit 290557 Questioned Costs: $1

Finding 369315 (2023-004)

Material Weakness 2023

Cleary University

MI

Questioned Costs Student Financial Aid Internal Control / Segregation of Duties

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the futu...

Incorrect and Untimely Return of Title IV Funds Calculation (R2T4) Planned Corrective Action: The University understands and concurs with the incorrect and untimely return of some Title IV funds. In response, the University has taken three (3) immediate steps to address this deficiency in the future. First, the institution has added financial aid staff with significant expertise and experience in the administration of the R2T4 process to periodically review standard and modular students R2T4 to ensure accurate, timely and compliant returns and reporting. Second, the University has identified policy and procedure improvements that align with best practice approaches to R2T4 administration in support of Pell recalculations and accurate return of funds. Finally, the institution has identified professional development opportunities for all financial aid, and associated personnel, to improve theoretical and practical awareness and implementation of the return process i.e., conference/webinar participation, in-house training workshops and discussions, identified liaison/unit champion roles, etc. Person Responsible for Corrective Action Plan: Michael Mathis, Director of Financial Aid Anticipated Date of Completion: January 2024

View Audit 290552 Questioned Costs: $1

Corrective Action Plans

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