Corrective Action Plans

Finding 1179 (2023-004)

Significant Deficiency 2023

AZ

HUD Housing Programs Reporting Significant Deficiency

Housing and Urban Development uses an Inventory Management System to review and monitor information submitted by public housing authorities through the 50058 form which is the system of record. To assist Scottsdale Housing Agency, HUD has developed the Public Information Center (PIC) Error Dashboard...

Housing and Urban Development uses an Inventory Management System to review and monitor information submitted by public housing authorities through the 50058 form which is the system of record. To assist Scottsdale Housing Agency, HUD has developed the Public Information Center (PIC) Error Dashboard that provides a summary analysis and overview of PIC errors. The PIC errors needing correction are updated on the first Tuesday of each month for Public Housing Agencies (PHA) to review and correct. The PIC errors identified were corrected in June 2023 through the monthly review and PIC submission. On average once corrections are submitted it takes 60‐90 days for the correction to be recognized and removed from the system. The Housing Choice Voucher Supervisor meets with the Housing Specialist monthly and resolves all PIC errors as a team effort.

View Audit 2251

Finding 1178 (2023-003)

Significant Deficiency 2023

City of Scottsdale, Arizona

AZ

Reporting Significant Deficiency Program Income

Program Income of $310,165 was recognized during FY 2022‐2023 through a substantial amendment to the Annual Action Plan adopted by the Mayor and City Council in January 2023. The Community Assistance Office followed the recommended guidelines of the Citizen Participation Plan to complete a substanti...

Program Income of $310,165 was recognized during FY 2022‐2023 through a substantial amendment to the Annual Action Plan adopted by the Mayor and City Council in January 2023. The Community Assistance Office followed the recommended guidelines of the Citizen Participation Plan to complete a substantial amendment as mandated. All program income was receipted correctly into the Integrated and Information Disbursement System (IDIS) for HUD. All program income funds have been reconciled through the Consolidated Action Plan 2020‐2025 and accurate PR26 have been completed and submitted through weekly meetings with the assigned representative since June of 2023.

View Audit 2251

Finding 1177 (2023-002)

Significant Deficiency 2023

City of Scottsdale, Arizona

AZ

Questioned Costs Special Tests & Provisions HUD Housing Programs

The Community Assistance Office completed a Housing and Urban Development (HUD) Environmental Review audit on February 14, 2023, resulting in a Corrective Action Plan to pay back funding for a statutory and regulatory violation of failure to retain an Authority to Use Grant Funds. A Corrective Actio...

The Community Assistance Office completed a Housing and Urban Development (HUD) Environmental Review audit on February 14, 2023, resulting in a Corrective Action Plan to pay back funding for a statutory and regulatory violation of failure to retain an Authority to Use Grant Funds. A Corrective Action Plan was submitted to HUD on March 10, 2023, that included the following most notable items: 1) Update environmental review policies to ensure compliance with 24CFR 58.22 with financial controls, retention, and the funding process, 2) Repayment of $255,750 to the CDBG line of credit and ensure no future CDBG funds are used for this purpose and 3) Staff training and development. Community Development Block Grant staff, including the supervisor and manager complete a webbased instruction system for environmental reviews through the HUD Exchange as recommended by October 31, 2023. In September 2023 two staff members attended an in person Environmental Review Training in San Francisco, CA through the Office of Environment and Energy. The $255,750 was repaid to the line of credit in two installments in June 2023 and August 2023. These funds will be re‐programmed for future eligible CDBG funding activities in the Annual Action Plan for FY 2024‐2025. Community Assistance Policies for financial controls, retention and the funding process will be updated and completed by January 1, 2024.

View Audit 2251 Questioned Costs: $1

Finding 1176 (2023-001)

Significant Deficiency 2023

City of Scottsdale, Arizona

AZ

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Complete all PR26 and PR29 for CDBG and CV by November 17, 2023. The Community Assistance Office met with Housing and Urban Development on a weekly basis to reconcile grant funds within the 2020‐2025 Five‐Year Consolidated Action Plan beginning June 9, 2023. Training was provided to Community Assist...

Complete all PR26 and PR29 for CDBG and CV by November 17, 2023. The Community Assistance Office met with Housing and Urban Development on a weekly basis to reconcile grant funds within the 2020‐2025 Five‐Year Consolidated Action Plan beginning June 9, 2023. Training was provided to Community Assistance Office staff through Housing and Urban Development and through Cloudburst Consulting to ensure key staff positions responsible for the completion of these reports is full trained. Develop a Master Calendar for the Community Assistance Office with re‐occurring reports to include the PR26, PR29 and including FFATA to ensure they are completed accurately and timely. PR26 for CDBG and PR29 for CDBG and CDBG‐CV have been submitted as of October 25, 2023, and the HUD concluded weekly meetings with the Scottsdale Community Assistance Office on October 20, 2023. PR26 for CDBG‐CV will be completed and submitted by November 17, 2023. Policies will be updated to reflect 2 CFR 170 requiring the City to submit subaward information through the Federal Funding Accountability and Transparency Act by the end of the month subsequent to an award.

View Audit 2251

Finding 1152 (2023-003)

Material Weakness 2023

Rio Housing Association, Inc. /covenant Place 075-Ee045

WI

Internal Control / Segregation of Duties Eligibility Material Weakness

Segregation of Duties Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: The Project should continue to evaluate its staffing in order to segregate incompatible duties whenever possible. Explanation of disagreement with audit finding: There is no disagreement with the...

Segregation of Duties Supportive Housing for the Elderly – Assistance Listing No. 14.157 Recommendation: The Project should continue to evaluate its staffing in order to segregate incompatible duties whenever possible. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The board of directors will continue to closely monitor the financial operations of the Project. Name(s) of the contact person(s) responsible for corrective action: Mary Gilberts, Management Agent Planned completion date for corrective action plan: June 2024

View Audit 2223

Finding 1139 (2023-001)

Significant Deficiency 2023

Magnolia Housing Corporation of Natchitoches, Inc.

LA

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Magnolia Manor has taken steps to assure that the Replacement Reserve account will not be underfunded again by making the transfer an automatic transfer from the Operating account to the Reserve account. The amount that the account was underfunded was deposited on September 26, 2023.

View Audit 2166

Finding 1127 (2023-002)

Material Weakness 2023

Ecorse Public Schools

MI

Material Weakness Reporting Internal Control / Segregation of Duties

Finding 2023-002, 2022-022 - Material Weakness in Internal Control over Financial Reporting and Material Noncompliance - Chart of Accounts Corrective Action Plan: The corrective action plan is to hire additional staff with expertise in the Uniform Budget and Accounting Act. All finance staff will b...

Finding 2023-002, 2022-022 - Material Weakness in Internal Control over Financial Reporting and Material Noncompliance - Chart of Accounts Corrective Action Plan: The corrective action plan is to hire additional staff with expertise in the Uniform Budget and Accounting Act. All finance staff will be required to take training in this area before December 31, 2023 and the CFO will initiate this action.

View Audit 2150

Finding 1118 (2023-001)

Significant Deficiency 2023

Drake University

IA

Student Financial Aid Reporting Significant Deficiency

Drake University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 to June 30, 2023 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assign...

Drake University respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 to 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—FINANCIAL STATEMENT AUDIT No findings to report. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University reevaluate its procedures and review policies surrounding reporting status changes to NSLDS to put a process in place to ensure the student status changes are being reported timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Subsequent to the final submission of the enrollment file to the NSC, the Registrar’s Office will manually update the enrollment status in the NSC for any student whose enrollment status was determined to have changed immediately upon the discovery of that change. This ensures that the enrollment status is updated for “unofficial withdrawals”, since the University’s date of determination that the student withdrew occurs after the end of the spring semester and often after the submission of the first enrollment file for the next semester. Prior to the 60-day reporting deadline (starting at the school’s date of determination that the student’s status changed) the Assistant Director for New Student Programs will verify that the enrollment status change is correctly reflected in NSLDS. In addition, the Financial Aid and Registrar’s Offices are exploring reports that are available from NSLDS to assist in identifying any discrepancies between University and NSLDS records. Name(s) of the contact person(s) responsible for corrective action: Kevin Moenkhaus, Associate Registrar Planned completion date for corrective action plan: September 30, 2023. If the Department of Education has questions regarding this plan, please call Ryan Zantingh at 515-271-3048.

View Audit 2147

Finding 1112 (2023-001)

None 2023

Cabun Rural Health Services, Inc.

AR

Reporting

Contact Name: Judy Southall, CFO Contact Phone Number: 870-798-4064 Audit Period Ending: March 31, 2023 Audit Firm: FORVIS, LLP Federal Program: Health Center Program, Assistance Listing Number: 93.224, 93.527 Federal Agency: U.S. Department of Health and Human Services Plan of action to correct fur...

Contact Name: Judy Southall, CFO Contact Phone Number: 870-798-4064 Audit Period Ending: March 31, 2023 Audit Firm: FORVIS, LLP Federal Program: Health Center Program, Assistance Listing Number: 93.224, 93.527 Federal Agency: U.S. Department of Health and Human Services Plan of action to correct further UDS issues. 1. Table 5, Line 8, Column b2 - Total number of Physician virtual visits were reported as 140. The support provided indicated a total of 141. a. Additional reports will be run to verify the number produced by the system on for virtual visits by providers. b. Totals will be verified against the canned report, additional reports, and what is entered into the HRSA handbook. 2. Table 5, Line 10a, Column b - Total number of NPs, PAs, and CNMs virtual visits were reported as 0, while the support provided indicated a total of 26. a. The report produced shows virtual encounters of 26 which could have been included under the billing provider (MD/DO) instead of performing provider (NP/PA) since the total visits were only 1 short. b. Additional reports will be run to verify the canned report produced by the PMS c. Totals of the canned reports, additional reports, and the HRSA entry will be verified for accuracy. 3. Table 5, Line 10a, Column b - Total clinic visits were reported as 21,494 rather than 21,495 based on the support. a. Additional reports will be run to verify the number produced by the system on the total clinic visits. b. Totals will be verified against the canned reports, additional reports and what is entered into the HRSA handbook.

View Audit 2123

Finding 1085 (2023-002)

Material Weakness 2023

Advance Community Health

NC

Reporting

Advance Community Health's CFO resigned and did not prepare the 3/31/2023 FFR prior to leaving in April 2023. The new CFO had to pick up where the former CFO left off with no transitional communication. The new CFO usually perform drawdowns along with the bi-weekly payroll which leaves no unobligate...

Advance Community Health's CFO resigned and did not prepare the 3/31/2023 FFR prior to leaving in April 2023. The new CFO had to pick up where the former CFO left off with no transitional communication. The new CFO usually perform drawdowns along with the bi-weekly payroll which leaves no unobligated balances at the end of the budget year. The New CFO assumed that the former CFO had done the same. The new CFO was not aware that a drawdown in the new fiscal year was for the prior fiscal year and prepared the FFR report with no unobligated balance. This should not pose an impact on any future FFR reporting due to the New CFO's practice of drawing down funds during the payroll week and having no unobligated balances at the end of the budget period. Tiffany Robertson, the CFO will be responsible for and will continue to assess our reporting processes for accuracy. We consider this issue to be fully resolved effective 10/27/2023.

View Audit 2069

Finding 1064 (2023-002)

Material Weakness 2023

Cgh Medical Center

IL

Material Weakness Reporting Internal Control / Segregation of Duties

COVID-19 Provider Relief Funding and American Rescue Plan Rural Distribution Recommendation: We recommend the Medical Center design controls to ensure that expenses are reported in accordance with latest HHS guidelines. Explanation of disagreement with audit finding: There is no disagreement with th...

COVID-19 Provider Relief Funding and American Rescue Plan Rural Distribution Recommendation: We recommend the Medical Center design controls to ensure that expenses are reported in accordance with latest HHS guidelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management has identified that the Medical Center has more than a sufficient amount of lost revenues related to COVID-19 to offset this difference. Action taken in response to finding: The Medical Center will ensure that controls are put into place to capture Covid specific costs in accordance with HHS guidelines. Name of the contact person responsible for corrective action: Megan Shank, COF. Planned completion date for corrective action plan: February 1, 2024

View Audit 2032

Finding 1063 (2023-001)

Significant Deficiency 2023

Cgh Medical Center

IL

Reporting Significant Deficiency Internal Control / Segregation of Duties

COVID-19 Provider Relief Funding and American Rescue Plan Rural Distribution Recommendation: We recommend the Medical Center design controls to ensure that lost revenues are reported in accordance with latest HHS guidelines. Explanation of disagreement with audit finding: There is no disagreement wi...

COVID-19 Provider Relief Funding and American Rescue Plan Rural Distribution Recommendation: We recommend the Medical Center design controls to ensure that lost revenues are reported in accordance with latest HHS guidelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Management has identified that the Medical Center has more than a sufficient amount of lost revenues related to COVID-19 to offset this difference. Action taken in response to finding: The Medical Center will ensure that controls are put into place to report lost revenues in accordance with HHS guidelines. Name of the contact person responsible for corrective action: Megan Shank, DOF. Planned completion date for corrective action plan: February 1, 2024

View Audit 2032

Finding 1025 (2023-001)

None 2023

Housing Authority of City of Covington

LA

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

Condition: The Section 8 program ended the year with a negative unrestricted equity of $6,810. A negative unrestricted equity balance is an indication that Housing Assistance Payments (HAP) funds are being spent on administration costs. Recommendation: The negative unrestricted equity balance should...

Condition: The Section 8 program ended the year with a negative unrestricted equity of $6,810. A negative unrestricted equity balance is an indication that Housing Assistance Payments (HAP) funds are being spent on administration costs. Recommendation: The negative unrestricted equity balance should be brought to a positive equity balance as soon as possible. Client Response and Corrective Action: The Executive Director will have the negative unrestricted equity balance corrected. Contact Person: Tammy Groover. Anticipated Date: March 31, 2024

View Audit 1935

Finding 1008 (2023-002)

Significant Deficiency 2023

Village Cooperative of Le Sueur

MN

Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Coopera...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 1911

Finding 1006 (2023-002)

Significant Deficiency 2023

Village Cooperative of Hutchinson

MN

Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Coopera...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 1910

Finding 1004 (2023-003)

Significant Deficiency 2023

Realife Cooperative of Bloomington

MN

HUD Housing Programs Reporting

Recommendation: We recommend that the Cooperative file their annual audit with the Federal Audit Clearinghouse within nine months of their fiscal year-end. Action Taken: The Cooperative will file their annual audit with the Federal Audit Clearinghouse within nine months of their fiscal year-end. ...

Recommendation: We recommend that the Cooperative file their annual audit with the Federal Audit Clearinghouse within nine months of their fiscal year-end. Action Taken: The Cooperative will file their annual audit with the Federal Audit Clearinghouse within nine months of their fiscal year-end. Planned Completion Date: January 24,2023

View Audit 1908

Finding 1003 (2023-002)

Significant Deficiency 2023

Realife Cooperative of Bloomington

MN

Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Coopera...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 1908

Finding 993 (2023-002)

Significant Deficiency 2023

Realife Cooperative of Eau Claire

WI

Reporting Internal Control / Segregation of Duties

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperati...

Recommendation: We recommend that the Cooperative continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Action Taken: The Cooperative will continue to review the auditor prepared adjusting journal entries and financial statements with the intention of understanding and acceptance of responsibility for reporting under generally accepted accounting principles. Planned Completion Date: Not Applicable.

View Audit 1887

Finding 991 (2023-001)

None 2023

Kenwood Place Ii, Inc.

IN

HUD Housing Programs Reporting

Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2023-001: Section 202 Capital Advance, CFDA 14.157 Recommendation: Make the required delinquent deposit to the replacement reserve account and ensure that a...

Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2023-001: Section 202 Capital Advance, CFDA 14.157 Recommendation: Make the required delinquent deposit to the replacement reserve account and ensure that all future deposits are made as required by the Regulatory Agreement. Action Taken: Management will make the required replacement reserve deposits as soon as possible and will ensure compliance in the future.

View Audit 1884

Finding 990 (2023-001)

None 2023

Kenwood Place I, Inc.

IN

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2023-001: Section 223(f) Loan Program, CFDA 14.155 Recommendation: Make the required delinquent deposit to the replacement reserve account and ensure that a...

Findings - Financial Statement Audit: None Findings - Federal Award Programs Audit: U.S. Department of Housing and Urban Development Finding 2023-001: Section 223(f) Loan Program, CFDA 14.155 Recommendation: Make the required delinquent deposit to the replacement reserve account and ensure that all future deposits are made as required by the Regulatory Agreement. Action Taken: Management will make the required replacement reserve deposits as soon as possible and will ensure compliance in the future.

View Audit 1882

Finding 959 (2023-004)

Material Weakness 2023

Bullock Creek School District

MI

Internal Control / Segregation of Duties Cash Management Material Weakness

October 24, 2023 Finding Number: 2023-004 – Material weakness in Internal Control – Reporting (Repeat Finding) Condition: In six of the eleven months tested, the number of meals included on the reimbursement claim reports were not supported by the District’s internal count sheets. Responsible Pe...

October 24, 2023 Finding Number: 2023-004 – Material weakness in Internal Control – Reporting (Repeat Finding) Condition: In six of the eleven months tested, the number of meals included on the reimbursement claim reports were not supported by the District’s internal count sheets. Responsible Person: Kim Gagne – Director of Food Service Implementation Date: 10-24-2023 This year we have partnered with Meal Magic, for reporting claims. Every student must enter an identification number or scan an ID card so that students cannot be missed or over-claimed. The Direct Certification students are compared monthly against the state information provided to make sure students are claimed at the correct rate. Sincerely, Stephen Grubaugh Director of Business Service

View Audit 1794

Finding 907 (2023-001)

Significant Deficiency 2023

John Brown University and Affiliates

AR

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

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: A new administrative withdrawal procedure has been created to ensure that Title IV is both timely and accurately returned to the Federal Government in the case of an official / unofficial withdrawal from the universit...

Inaccurate and Untimely Return of Title IV Funds (R2T4) Planned Corrective Action: A new administrative withdrawal procedure has been created to ensure that Title IV is both timely and accurately returned to the Federal Government in the case of an official / unofficial withdrawal from the university. A shared Office365 document was created to track the number of days in each segment of the withdrawal process. The Student Financial Services (SFS) Representative initiates the process upon notification of withdrawal from the Registrar. Appropriate documentation is gathered at the time of withdrawal to establish the correct timeline for the potential return of Title IV funds. The SFS Representative then determines if an R2T4 calculation is required. If an R2T4 calculation is required, the SFS Representative will assign the task to the Student Loan Processor or the Director of Student Financial Services. The Student Loan Processor and Director of Student Financial Services will use Microsoft Outlook, as prompted by the shared Office365 document, to assign “due dates” for both the R2T4 calculation as well as the return of funds to COD to ensure compliance. The Director of Student Financial Services and the Chief Student Finance Officer will perform a weekly review of the shared Office365 document to confirm the accuracy of R2T4 calculations and the required timeline of the return of Title IV funds. A secondary review by a financial aid representative with the appropriate level of experience will ensure that internal controls over such processes can operate effectively and achieve compliance. Person Responsible for Corrective Action Plan: David Burney, Chief Student Finance Officer Anticipated Date of Completion: Implemented August 21, 2023

View Audit 1692

Finding 905 (2023-002)

Significant Deficiency 2023

Litchfield Community Unit School District No. 12

IL

Reporting Internal Control / Segregation of Duties

2023-002 Condition: The District’s general ledger expense account functions and objects do not agree to the account functions and objects that were reported to the Illinois State Board of Education on the quarterly expenditure reports and budgets approved by the Illinois State Board of Education. ...

2023-002 Condition: The District’s general ledger expense account functions and objects do not agree to the account functions and objects that were reported to the Illinois State Board of Education on the quarterly expenditure reports and budgets approved by the Illinois State Board of Education. Recommendation: The District should ensure that the expenditure reports filed with the Illinois State Board of Education are reconciled with the general ledger accounts of the District prior to submission. Management Response: The District will take the necessary steps to reconcile the expenditure reports with the general ledger accounts before submitting to the Illinois State Board of Education. Anticipated Date of Completion: June 30, 2024

View Audit 1684

Finding 846 (2023-001)

Material Weakness 2023

Madison County Housing Authority

NC

Special Tests & Provisions Cash Management HUD Housing Programs

Noncompliance with Special Tests and Provisions – Obligations of 1406 Budget Line Item Draws (Public Housing Capital Fund CFDA 14.872) We will ensure all future CFP 1406 Operations Draws are made before amounts are reported as Obligated in ELOCCS. Date of completion: October 18, 2023

View Audit 1614

Finding 842 (2023-001)

Significant Deficiency 2023

Missouri Baptist University

MO

Student Financial Aid Subrecipient Monitoring Reporting

Regarding student status change reporting, we identified a primary issue as the cause of late reporting this year for 32 of the 33 issues identified by our auditors. Upon review, we have determined changes that will prevent future instances of late reporting. As would be known to the federal govern...

Regarding student status change reporting, we identified a primary issue as the cause of late reporting this year for 32 of the 33 issues identified by our auditors. Upon review, we have determined changes that will prevent future instances of late reporting. As would be known to the federal government, a website and database conversion of the National Student Loan Data System (NSLDS) made enrollment reporting unavailable to schools for most of the academic year. One consequence to this was that the National Student Clearinghouse (NSC), transitioned away from what they refer to as a mid-month roster response. It was not known to us that the NSC was not regularly submitting mid-month response files to NSLDS after enrollment reporting resumed in January of 2023. Our monthly enrollment SSCR file is scheduled to be sent to the NSC on the first of each month. Our scheduled graduation date is the end of April or start of May, so we typically send an updated graduated student list around the middle of May. We were delayed from submitting this until the first week of June. The data submission was too late to be caught by the June 1st SSCR sent by NSLDS, but we expected that it would be sent by the mid-month file sent by NSC to NSLDS around June 15th. This would have kept us within 60 days for reporting. However, since NSC did not conduct mid-month reporting in June, the data we submitted indicating graduations that occurred at the end of April/start of May sat until July 1st with NSC and it was not sent to NSLDS within 60 days. Conversations we have had with the NSC since this discovery assured us that they have resumed mid-month reporting as of July, 2023. Additionally, our analyst with the NSC assured us they would track our transmission schedule to know if data is refreshed and current at the time of their responses to the first of month SSCR files they receive from NSLDS. When the data we send comes through after a scheduled SSCR file has been processed, they will reach out to inform us of a mid-month roster being sent. To provide accountability toward this, we will make it our process to check with them on whether a mid-month roster will be sent also. When NSC does not expect to send mid-month files automatically, we will order an ad-hoc enrollment report from the NSLDS website. We experimented with this process in recent months when we became aware of this issue with mid-month reporting and found it successful. In discussion with NSC and NSLDS, we inquired as to whether we should simply increase the frequency of our NSLDS SSCR to twice per month. For the majority of the year, this is not necessary. It was a unique situation this year in that mid-month reporting had ceased following the NSLDS Enrollment Reporting being offline for half or our academic year. For one additional student in the sample, an error was found with our student information system not updating the effective date of their enrollment change. Our software vendor was asked about the conditions of this error. They had made a modification to the reporting logic early on this past year, and this logic has proven to be inaccurate. The issue was not apparent through most of the year because enrollment reporting was not being conducted because of the previously mentioned NSLDS website transitions. Upon learning of the error, our software vendor updated their logic and has issued a patch that will correctly update the enrollment status effective date. All corrective actions will be fully implemented by October 31, 2023.

View Audit 1585

Corrective Action Plans

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