Corrective Action Plans

Finding 513486 (2024-001)

Significant Deficiency 2024

MA

HUD Housing Programs Eligibility Significant Deficiency

Finding 2024-001- Housing Choice Voucher Tenant Files - Eligibility- Rent Calculations Noncompliance & Significant Deficiency Section 8 Housing Choice Voucher Cluster-ALNs 14.871 and 14.879 Corrective Action Plan: Finding: Somerville Housing Authority (SHA) received the authority's Single Audit for ...

Finding 2024-001- Housing Choice Voucher Tenant Files - Eligibility- Rent Calculations Noncompliance & Significant Deficiency Section 8 Housing Choice Voucher Cluster-ALNs 14.871 and 14.879 Corrective Action Plan: Finding: Somerville Housing Authority (SHA) received the authority's Single Audit for the year ended March 31, 2024, indicating that SHA received a finding of Significant Deficiencies. Auditors noted two files missing proper income verification, five containing miscalculation of income, and one missing deduction verification. Extrapolation of errors to the population found the potential misstatement to be immaterial to program HAP expense. Auditors recommend that SHA conduct a file audit to determine the extent of deficiencies. They also recommend that SHA implement a quality control review to monitor the maintenance of tenant files. PHA Response: The SHA has implemented a corrective action plan to address noted deficiencies. The SHA has had significant staffing turnover in the last year. While vacant positions were filled, the SHA contracted with Nan McKay Associates (NMA) to complete all Annual Recertifications. NMA assigned four full-time staff to complete all recertifications and assigned one additional full-time staff person to conduct a monthly Qualify Control Review of all recertifications completed by NMA. During NMA's contract, SHA focused hiring and training new staff. SHA has hired a new Director of Leased Housing, a new Leased Housing Supervisor, and three Leasing Coordinators. SHA is also in the process of promoting it's Tenant Selector to Leasing Coordinator and onboarding a new Tenant Selector. The Director and Supervisor have been providing one-on-one training and support. New staff have also been enrolled in training opportunities provided by outside vendors such as the Nan McKay Rent Calculation Class. As of 7/31/2024, SI-IA has resumed program management from NMA. SHA has also increased the agency's internal quality control audits. The Director of Leased Housing has increased monthly SEMAP review from 10 to 40 files. Monthly feedback is provided to staffers individually and systemic issues are addressed to the entire department. The Supervisor also conducts a monthly review of the Income Verification Tool, following up with staffers to assist them in addressing discrepancies with their client's records. Additionally, SHA has fully implemented an electronic file storage system, utilizing PHA Web's online system to better organize, track, and maintain client files. Since implementation of the corrective action plan, 100% of reviewed files were found to have appropriate Payment Standards, 99% have appropriate third party documentation, and 98% have appropriate adjusted income. 84% were found to have appropriate Utility Allowances. Corrective action has been taken on all errors, and guidance has been provided to staff. Staff are currently conducting a front to back audit of Utility Allowances. SHA will continue conducting file audits, as well as following up with staff. PHA Goal: Based on the SHA's monthly quality control sample of tenant files: (A) The SHA obtains third party verification of reported family annual income, the value of assets totaling more than $5,000, expenses related to deductions from annual income, and other factors that affect the determination of adjusted income, and uses the verified information in determining adjusted income, and/or documents tenant files to show why third party verification was not available; (B) The SHA properly attributes and calculates allowances for any medical, child K:are, and/or disability assistance expenses; and (C) The SHA uses the appropriate utility allowances to determine gross rent for the unit leased, (D) The SHA applies the appropriate payment standard in accordance with 24 CFR 982.505. PHA Strategies: 1) The SHA will review its current quality control tracking system to record the results of random sampling of files as required in 985.2. The SHA will revise this system of an ongoing basis if necessary. Targeted completion date: 3/31/2025. 2) Confirm that 90% or more files sampled contain proper third party written verification (or equivalent) of income and assets, proper calculation of appropriate deductions and allowances and that appropriate utility allowance were used in the calculation of tenant rent. Targeted completion date: 3/31/2025. Person Responsible: Matt Lincoln, Director of Leased Housing Daved Hospedales, Leased Housing Supervisor

View Audit 331370

Finding 513473 (2024-001)

Significant Deficiency 2024

Basis Texas Charter Schools, Inc.

TX

Procurement, Suspension & Debarment Significant Deficiency Internal Control / Segregation of Duties

Subject: Management Response to FY 2024 Audit Findings The management of BASIS Texas Charter School, Inc. acknowledge receipt of the following finding for the audit year FY 2024. While agreeing with the findings, management submits the following as its response: Finding 2023-001: Procurement – Signi...

Subject: Management Response to FY 2024 Audit Findings The management of BASIS Texas Charter School, Inc. acknowledge receipt of the following finding for the audit year FY 2024. While agreeing with the findings, management submits the following as its response: Finding 2023-001: Procurement – Significant deficiency in internal control over compliance finding. Management Response Management will develop a tracking system to ensure all new personnel receives the required procurement and purchase training prior to having the ability to engage in any purchases. Parties Responsible: VP of Accounting Accounts Payable and Procurement Manager Senior Accountant The Corrective Action Plan will be put in place no later than January 1, 2025. Please let us know if you have any questions. Andrew Freeman Executive Director

View Audit 331353

Finding 513460 (2024-001)

Significant Deficiency 2024

Middle Kentucky Community Action Partnership, Inc.

KY

Subrecipient Monitoring Reporting Significant Deficiency

Management agrees with the finding and has committed to a corrective action plan. Middle Kentucky has the use of a scheduling calendar in which required dates of reports and other key events are now placed. Middle Kentucky CFO has added the dates of reports including the FSRS report and its due date...

Management agrees with the finding and has committed to a corrective action plan. Middle Kentucky has the use of a scheduling calendar in which required dates of reports and other key events are now placed. Middle Kentucky CFO has added the dates of reports including the FSRS report and its due date. From this calendar an alert can and will e sent to the CFO and a designated second person to alert them as to the upcoming required date that this and other reports are to be submitted. The calendar both electronic and in written form is now in use and no further instances of this occurrence should occur within the fiscal department in the future.

View Audit 331309

Finding 513458 (2024-001)

Significant Deficiency 2024

Gateway Techincal College District

WI

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education Gateway Technical College District respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings ...

U.S. Department of Education Gateway Technical College District respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 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 Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2024-001 Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend that the District review its processes and internal controls designed to mitigate the risk of noncompliance with the stated criteria to ensure the information reported to NSLDS is consistent with District records. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will take corrective action to correct the information for the one (1) exception noted in the audit. In addition, the District will review its procedures for the transmission of the required data to the National Student Clearinghouse, which assists the District in transmitting the data to the National Student Loan Data System. This review will include consideration of process enhancement to mitigate the risk of the error occurring again in future submissions. Name of the contact person responsible for corrective action: Travis Jansen, Registrar Planned completion date for corrective action plan: June 30, 2025 *** If the U.S. Department of Education has questions regarding this plan, please call Travis Jansen, Registrar at 262-564-2450.

View Audit 331307

Finding 513383 (2024-003)

Significant Deficiency 2024

Platte Health Center

SD

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: The Health Center does not have a formally documented review and approval process in place to ensure compliance with the debt service co...

Federal Agency Name: Department of Agriculture Program Name: Communities Facilities Loans and Grants Federal Financial Assistance Listing #10.766 Finding Summary: The Health Center does not have a formally documented review and approval process in place to ensure compliance with the debt service coverage ratio and working capital calculations. Responsible Individuals: Vicki Jensen, Chief Financial Officer Corrective Action Plan: Platte Health Center will perform debt service ratio and working capital calculations as part of their year-end close process. The calculations will be reported to the Board of Directors and be recorded in the meeting minutes. Anticipated Completion Date: June 30, 2025

View Audit 331222

Finding 513202 (2024-002)

Significant Deficiency 2024

Moore County, North Carolina

NC

Eligibility Significant Deficiency

Finding: 2024-002, Significant Deficiency over Eligibility Name of Contact Person: David Richmond, Director Corrective Action/Management’s Response: No financial costs are associated with findings. Refresher trainings on household member relationships verification will be held with all Family and ...

Finding: 2024-002, Significant Deficiency over Eligibility Name of Contact Person: David Richmond, Director Corrective Action/Management’s Response: No financial costs are associated with findings. Refresher trainings on household member relationships verification will be held with all Family and Children Medicaid Workers. Ten Targeted second party reviews will be completed by Quality Assurance Team to monitor compliance with policy. Workers are held accountable for outcomes/actions for correct eligibility determination of cases. Proposed Completion Date: All training for corrective action refresher training will be completed by March 31, 2025. Targeted second parties will begin December 2024 and continue.

View Audit 331145

Finding 513148 (2024-001)

Significant Deficiency 2024

Central Wyoming College

WY

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

The Student Financial Aid Office and The Office of Student Records will work closely to ensure students date of withdrawal from all courses are entered into Colleague correctly and that both offices dates match. The Office of Student Records will provide the National Clearinghouse enrollment reporti...

The Student Financial Aid Office and The Office of Student Records will work closely to ensure students date of withdrawal from all courses are entered into Colleague correctly and that both offices dates match. The Office of Student Records will provide the National Clearinghouse enrollment reporting dates for Central Wyoming College to the Financial Aid Office. This will ensure the Financial Aid Office provides the Office of Student Records the Return to Title IV student report in a timely manner for reporting to the Clearinghouse. The Registrar will make sure any student on the Return to Title IV list has a record on the National Clearinghouse for program - level and campus- level reporting. The Registrar will verify all students on the Return to Title IV list are showing correctly on the Clearinghouse upon submittal. The Director of Financial Aid and the Registrar will meet monthly to review the Return to Title IV lists provided to the Registrar match NSLDS to ensure status dates for all Return to Title IV students are accurately reflected. The Director of Financial Aid will also communicate any issues found with statuses on the NSLDS site with the Registrar. The Director of Financial Aid in collaboration with the Office of Student Records will work to obtain and review the SOC1 report from the third-party servicer (Clearing house) to ensure proper controls are implemented. Anticipated Completion Date – December 1, 2024 Contact Person(s) – DeeAnna Archuleta, SFA Director Connie Nyberg - Registrar

View Audit 331134

Finding 513120 (2024-002)

Significant Deficiency 2024

Hodges University, Inc.

FL

Student Financial Aid Reporting Significant Deficiency

Common Origination and Disbursement (COD) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for ...

Common Origination and Disbursement (COD) Reporting Recommendation: We recommend that the University review their reporting policies and procedures to ensure accurate and timely reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The previous corrective action plan failed to fully address this finding. Action taken in response to finding: Not Applicable- No corrective action will be made, Hodges University closed on August 25th, 2024. Name(s) of the contact person(s) responsible for corrective action: Not Applicable Planned completion date for corrective action plan: Not Applicable

View Audit 331081

Finding 513119 (2024-001)

Significant Deficiency 2024

Hodges University, Inc.

FL

Student Financial Aid Reporting Significant Deficiency

National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement ...

National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend that the University review their policies and procedures to ensure accurate reporting and responding to enrollment rosters to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Reason for finding: The previous corrective action plan failed to fully address this finding. Action taken in response to finding: Not Applicable- No corrective action will be made, Hodges University closed on August 25th, 2024. Name(s) of the contact person(s) responsible for corrective action: Not Applicable Planned completion date for corrective action plan: Not Applicable

View Audit 331081

Finding 513101 (2024-001)

Significant Deficiency 2024

Southwestern Law School

CA

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Southwestern Law School provides the following corrective action plan for the finding Moss Adams, LLP identified during the Southwestern's federal awards audit for the year ending June 30, 2024. Southwestern acknowledges the finding and recommendation from Moss Adams. Finding 2024-001 - Special Te...

Southwestern Law School provides the following corrective action plan for the finding Moss Adams, LLP identified during the Southwestern's federal awards audit for the year ending June 30, 2024. Southwestern acknowledges the finding and recommendation from Moss Adams. Finding 2024-001 - Special Tests and Provisions - Enrollment Reporting: Significant Deficiency in Internal Control over Compliance. Responsible Offices and Individuals: Improving procedures around enrollment reporting is the joint responsibility of the Registrar's Office and the Information Office. Eileen Zwiers, Registrar, and Sean Murphy, Chief Information Officer, are responsible for implementing the corrective action plan. Corrective Action Plan: Southwestern has prepared and implemented a new Enrollment Reporting Policy to ensure Title IV compliance when reporting changes in student enrollment status to the National Student Loan Data System. The policy outlines Southwestern's procedures for timely, accurate and complete through the National Student Clearinghouse. Additionally, the Financial Aid Office will conduct monthly audits of reported submissions directly from the National Student Loan Data System portal to ensure accuracy. The Financial Aid Office documents and securely stores these verified submissions to support the federal audit, in compliance with federal retention and data management policies. Anticipated Completion Date: Southwestern took immediate action to improve the policies and procedures around enrollment reporting. The remediation was appropriately completed September 2024. Sincerely, Eileen Zwiers Registrar Sean Murphy Chief Information Officer

View Audit 331074

Finding 513086 (2024-002)

Material Weakness 2024

Housing Authority of the City of Paterson

NJ

Questioned Costs HUD Housing Programs Material Weakness

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Voucher & Emergency Housing Vouchers Assistance Listing Number: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Complia...

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Voucher & Emergency Housing Vouchers Assistance Listing Number: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Material to the Financial Statements: Section 8 Housing Choice Vouchers - Yes Emergency Housing Vouchers - No Material Weakness and Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions. Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets the Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussions with management, the Authority did not properly abate fifteen (15) out of twenty-nine (29) annual failed inspections selected for testing. Context: The Authority did not properly abate fifteen (15) out of twenty-nine (29) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Our sample size is statistically valid. Known Questioned Costs: Section 8 Housing Choice Vouchers $50,873 Emergency Housing Vouchers $1,308 Cause: There is a material weakness in Section 8 Housing Choice Vouchers and a significant deficiency in Emergency Housing Vouchers in internal controls over compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to HQS inspections and the Emergency Housing Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: We agree with the Auditor’s observations on the re-inspection of the failed units. The Authority had an independent contractor whose contract was terminated due to their unacceptable performance with HQS inspections. As a result, two HQS inspectors were recently hired, and a clerical person to assist in improving the quality control component of the program as it relates to HQS inspections. In addition, the Authority recently hired a Director of Leasing and Occupancy, and a Supervisor of the department, and has implemented a more stringent oversight to ensure that internal control policies are being followed in a timely manner to show improvement in this area, and an overall improvement to the entire function of this department. We are also actively seeking to fill two vacant Tenant Interviewer/Investigator positions. The current staffing change mentioned above puts the agency in a position to implement and ensure a tracking system being able to capture areas on Annual HQS unit status, First Inspection if failed for life threatening HQS deficiencies rescheduled within 24 hours and 30 days for all other deficiencies. Abatements are placed on all units having two failed HQS inspections. All current occupied units are being reviewed for HQS inspection status, and a resolving issues to those units not in compliance with the program. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2025.

View Audit 331015 Questioned Costs: $1

Finding 513063 (2024-001)

Significant Deficiency 2024

Tahquamenon Area Schools

MI

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.326

Corrective Action: The District will be proactive with adherence to all federal requirements, including, but not limited to prevailing wage rate provisions with any contracts moving forward. Additionally, the district will be aware of the need to adhere to these federal requirements when funding str...

Corrective Action: The District will be proactive with adherence to all federal requirements, including, but not limited to prevailing wage rate provisions with any contracts moving forward. Additionally, the district will be aware of the need to adhere to these federal requirements when funding streams are blended. The district has already started communication to relay that federal prevailing wage rates should have been utilized. Responsible Person: Nicole Eilola, Shared Services Business Manager & Stacy Price, Superintendent. Anticipated Completion Date: Immediate

View Audit 330975

Finding 513006 (2024-001)

Significant Deficiency 2024

City of High Point, North Carolina

NC

Subrecipient Monitoring Period of Performance Reporting

Finding 2024-001, Significant Deficiency - Reporting In Fiscal Year 2023-24, the Transportation Department submitted reports for the RAISE grant to the NCDOT for four quarters without prior review from the Finance Department. This was corrected with the June 2024 quarterly report, and the grant liai...

Finding 2024-001, Significant Deficiency - Reporting In Fiscal Year 2023-24, the Transportation Department submitted reports for the RAISE grant to the NCDOT for four quarters without prior review from the Finance Department. This was corrected with the June 2024 quarterly report, and the grant liaison is now following the City's policy. The liaison prepares the report and sends it to his manager for review and approval. Then it is routed to the Senior Financial Grants Analyst for review. The Accounting Manager reviews and approves the report before it is submitted to the NCDOT. The Transportation Department has been made aware that the City needs to follow the grants policy with all grants. Implemented prior to report date. Greg Venable, Transportation Director, Responsible Person 11/26/24 Bobby Fitzjohn, Financial Services Director 11/26/24

View Audit 330903

Finding 513002 (2024-001)

Significant Deficiency 2024

Independent School District 719 Prior Lake-Savage Area Schools

MN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties School Nutrition Programs § 200.318

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553 AND 10.559 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Findi...

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.553 AND 10.559 2024-001 Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary - 2 CFR § 180 and 2 CFR § 200.318-327 requires Independent School District No. 719, Prior Lake-Savage Area Schools (the District) to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster federal programs. During our audit, we noted the District did not have sufficient controls in place within its child nutrition cluster federal programs to ensure compliance with federal requirements related to assuring that the District was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs to ensure compliance with the Uniform Guidance in the future. The review of procedures will also include steps to assure that district personnel are following the requirements of the Uniform Guidance related to suspension and debarment, including maintaining appropriate documentation. Official Responsible – The District’s Executive Director of Business Services, Tammy Fredrickson. Planned Completion Date – June 30, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – The District’s Executive Director of Business Services, Tammy Fredrickson, will assure appropriate internal controls and procedures are in place to ensure compliance with suspension and debarment requirements.

View Audit 330889

Finding 513001 (2024-004)

Significant Deficiency 2024

Universidad Carlos Albizu, Inc.

PR

Student Financial Aid Eligibility Reporting

Finding No. 2024-004 Delay in Direct Loan Adjustment After Enrollment Cancellation Condition Found During our eligibility test, we identified a situation in which a student's enrollment was canceled after Pell and Direct Loan funds had already been credited to the student's account. Even though the ...

Finding No. 2024-004 Delay in Direct Loan Adjustment After Enrollment Cancellation Condition Found During our eligibility test, we identified a situation in which a student's enrollment was canceled after Pell and Direct Loan funds had already been credited to the student's account. Even though the Pell Grant adjustment and return to COD were completed promptly, the adjustment for the Direct Loan was only made after the auditor discovered that the loan had not been properly adjusted and returned to the Department of Education. Corrective Action Plan We will thoroughly explore system capabilities, and a targeted training session in the Ellucian software will be developed and scheduled to directly address the identified deficiency. All Student Financial Aid Officers will be required to complete this mandatory training. Additionally, comprehensive internal monitoring exercises will be conducted for all R2T4 events to ensure full compliance and process integrity. Name(s) of the Contact Person(s) Responsible for Corrective Action Doris Quero, Senior Financial Aid director Carmen Rivera Laboy, Title IV Compliance Coordinator Eliezer Rodriguez, Ellucian Specialist Anticipated Completion Date Will be completed on or before December 15, 2024.

View Audit 330883

Finding 513000 (2024-003)

Significant Deficiency 2024

Universidad Carlos Albizu, Inc.

PR

Student Financial Aid Subrecipient Monitoring Reporting

Finding No. 2024-003 Late R2T4 reimbursement to ED Condition Found In testing compliance with the return of Title IV funds requirement, we noted three (3) cases, or eight percent (8%), of the sample selected, in which the University failed to return the total corresponding refund within 45 days from...

Finding No. 2024-003 Late R2T4 reimbursement to ED Condition Found In testing compliance with the return of Title IV funds requirement, we noted three (3) cases, or eight percent (8%), of the sample selected, in which the University failed to return the total corresponding refund within 45 days from the date the University determined that the student withdrew, dropped-out, or failed to attend to the University. Corrective Action Plan The institution will enhance the total withdrawal process by assigning a dedicated financial aid officer to each campus, responsible for overseeing all funds. This officer will be solely accountable for determining whether a withdrawal is official or unofficial, executing the Return of Title IV (R2T4) process, and coordinating with the fiscal department to ensure timely completion of refunds. As a further safeguard, the Title IV Compliance Coordinator will rigorously monitor the effectiveness of this corrective action plan and ensure ongoing compliance. Name(s) of the Contact Person(s) Responsible for Corrective Action Doris Quero, Senior Financial Aid Director Carmen Rivera Laboy, Title IV Compliance Coordinator Anticipated Completion Date Will be completed on or before January 15, 2025.

View Audit 330883

Finding 512999 (2024-002)

Significant Deficiency 2024

Universidad Carlos Albizu, Inc.

PR

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

Finding No. 2024-002 Late Refund Issuance Condition Found During our evaluation of compliance with these requirements, we noted one (1) instance, or six percent (6%) of the sample selected, in which the University failed to return the corresponding refund within 14 days’ time frame from the date the...

Finding No. 2024-002 Late Refund Issuance Condition Found During our evaluation of compliance with these requirements, we noted one (1) instance, or six percent (6%) of the sample selected, in which the University failed to return the corresponding refund within 14 days’ time frame from the date the University determined that the student had a Federal Student Aid (FSA) credit balance. Forty-one (41) days passed between the date the University identified an FSA credit balance for the student and the actual refund to the student. Corrective Action Plan We will aggressively pursue systems automation alternatives to streamline operations and enforce interdepartmental collaboration to ensure strict compliance with deadlines. Additionally, we will deliver targeted cash management training, with a strong focus on rigorously reviewing and optimizing refund processing procedures. Name(s) of the Contact Person(s) Responsible for Corrective Action Héctor L. Peña, Director of Finance Ramón L. Menéndez, CFO Dr. Antonio Llorens, CIO Anticipated Completion Date Will be completed on or before January 15, 2025.

View Audit 330883

Finding 512995 (2024-001)

Significant Deficiency 2024

West Shore Community College

MI

Special Tests & Provisions Reporting Significant Deficiency

Auditor Description of Condition and Effect. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that perio...

Auditor Description of Condition and Effect. The Code of Federal Regulations, 34 CFR 668.22(f)(2)(i), states that scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in the period of enrollment and the number of calendar days completed in that period. It was noted during our testing of R2T4 calculations that the College is not excluding the correct number of days for scheduled breaks of five days or more in both the 2023 fall and 2024 spring terms. Thus, all calculations performed for both of these terms were determined to be inaccurate. Incorrect break days were used in the calculation due to an error in the entering of the College's academic schedule information into the PowerFAIDS system, resulting in incorrect dates being used in the preparation of refund calculations within the system. As a result of this condition, the students' return of funds calculation was not done correctly and the return of funds back to the federal government was for the incorrect amount. No costs are required to be questioned as the amounts did not exceed the reporting threshold. Auditor Recommendation. We recommend the College review the R2T4 requirements and implement procedures to ensure the R2T4 calculations are using the correct amount of term days. Corrective Action. The Director of Financial Aid has reviewed the R2T4 requirements in detail and have implemented enhanced procedures to ensure accurate R2T4 calculations moving forward. One of the key steps in the College's corrective action plan is to introduce a more rigorous review process when developing our annual academic calendars. This includes conducting a pre-term audit of the calendar to verify the total number of term days, including the correct designation of non-instructional days, when developing the proposed academic calendar. Once cross-checking against R2T4 requirements has been completed, the Registrar will bring the proposed calendar to the College’s Institutional Effectiveness Team. This group will then serve as an additional review panel and approval body to ensure all term days, including breaks, are accurately reflected to prevent future discrepancies in the R2T4 calculations. Responsible Party. The Dean of Student Services will take primary responsibility for overseeing this process and ensuring accuracy and R2T4 compliance. Anticipated Completion Date. The corrective action plan is already in progress, with full implementation expected by June 30, 2025.

View Audit 330866

Finding 512975 (2024-002)

Significant Deficiency 2024

Certell, INC

IN

Questioned Costs Student Financial Aid Reporting

Finding 2024-002: Inaccurate Reporting of Disbursement Dates to the Common Origination and Disbursement (COD) System – It is recommended the Institution correct the disbursement dates in COD and tighten controls over reporting disbursements dates. Comments on Finding and Recommendation(s): HJC con...

Finding 2024-002: Inaccurate Reporting of Disbursement Dates to the Common Origination and Disbursement (COD) System – It is recommended the Institution correct the disbursement dates in COD and tighten controls over reporting disbursements dates. Comments on Finding and Recommendation(s): HJC concurs with the finding. The transition to a new SIS system created import and export issues affecting disbursement date posting. Actions Taken or Planned: HJC has entered into an agreement with Global Financial Aid Services (GF AS) to process Title IV financial aid beginning with new 2024-25 aid packaged in the Fall 2024 quarter. Global processing the aid with HJC backing up and reviewing will ensure accurate date reporting to COD. The dates in question have been updated at COD.

View Audit 330798 Questioned Costs: $1

Finding 512974 (2024-005)

Significant Deficiency 2024

Certell, INC

IN

Student Financial Aid Reporting Significant Deficiency

Finding 2024-005: Untimely Enrollment Status Reporting – It is recommended the Institution increase controls over enrollment reporting. Comments on Finding and Recommendation(s): After the transition to Campus Cafe had begun, it was determined that they did not have the capability of importing NSL...

Finding 2024-005: Untimely Enrollment Status Reporting – It is recommended the Institution increase controls over enrollment reporting. Comments on Finding and Recommendation(s): After the transition to Campus Cafe had begun, it was determined that they did not have the capability of importing NSLDS enrollment reporting reports as our previous system had, so FA staff has been updating enrollment information manually. Actions Taken or Planned: HJC has initiated discussions with the Clearinghouse for NSLDS reporting purposes. As a recent ECAR is required to complete the contract, we are currently waiting on an updated EApp to be processed to complete the process.

View Audit 330798

Finding 512965 (2024-002)

Significant Deficiency 2024

Stanly County

NC

Subrecipient Monitoring Eligibility Reporting

Finding 2024-002 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-003 Inadequate Request For Information Name of contact person: Corrective Action: Section III - Federal Award Findings and Question Costs The County will make it a practice...

Finding 2024-002 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2024-003 Inadequate Request For Information Name of contact person: Corrective Action: Section III - Federal Award Findings and Question Costs The County will make it a practice going forward of calculating the correct net present values recorded for all GASB 87 leases. The prior period adjustments from the previous year did not involve GASB 87 leases and have been remedied. Immediately. Corrective Action Plan For the Year Ended June 30, 2024 Section II - Financial Statement Findings Robin Huneycutt, Family and Children's Medicaid Supervisor Unit training to discuss accuracy of income and HH size calculations, proper information is included in the case file and necessary procedures are taken when determining eligibility. This will include the importance of documentation of caseworker actions and results from actions. Robin Huneycutt held training with her staff on 10/24/2024 to discuss these deficiencies.

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Finding 512924 (2024-003)

Significant Deficiency 2024

Wake County, North Carolina

NC

Allowable Costs / Cost Principles Reporting Student Financial Aid

Finding 2024-003 Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principle; Foster Care -Title IV-E (Foster Care), Assistance Listing Number 93.658, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCD...

Finding 2024-003 Significant Deficiency over Activities Allowed and Unallowed and Allowable Costs/Cost Principle; Foster Care -Title IV-E (Foster Care), Assistance Listing Number 93.658, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Social Services. Medicaid Cluster (Medicaid), Assistance Listing Number 93.778, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Medical Assistance. Supplemental Nutrition Assistance Program (SNAP) Cluster, Assistance Listing Number 10.561, 10.561-COVID, U.S. Department of Agriculture, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Social Services. Recommendation: We recommend that the County implements a review control over weekly timesheets to ensure the timesheets include all program time coded on the day sheets. Corrective Action Plan: The county will conduct training on day sheet and time sheet processes. The county will complete random monthly reviews of day sheets and timesheets. For those staff identified by the random monthly review with discrepancies, supervisors will provide refresher training on day sheet and timesheet procedures. Additional targeted reviews will be completed monthly until the deficiencies are corrected. Proposed Completion Date: 1/31/2025 for initial department training 2/28/2025 initiate random monthly reviews of day sheets and timesheets 7/31/2025 for additional reviews as needed for identified staff and refresher trainings Name of Contact Person: Yolanda Mcinnis, Economic Services Division Director and Sheila Donaldson Child Welfare Division Director

View Audit 330686

Finding 512923 (2024-002)

Significant Deficiency 2024

Wake County, North Carolina

NC

Eligibility Significant Deficiency Equipment & Real Property Management

Finding 2024-002 Significant Deficiency over Eligibility (Repeat Finding); Medicaid Cluster (Medicaid), Assistance Listing Number 93. 778, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Medical Assistance. Recommen...

Finding 2024-002 Significant Deficiency over Eligibility (Repeat Finding); Medicaid Cluster (Medicaid), Assistance Listing Number 93. 778, U.S. Department of Health and Human Services, passed through the N.C Department of Health and Human Services (NCDHHS), Division of Medical Assistance. Recommendation: We recommend that the County train and monitor employees on the eligibility determination process. We also recommend the County review and amend current policies and procedures in place to ensure that all eligibility determination documentation is completed and retained by the County. Corrective Action Plan: The county will complete a quarterly review of errors in citizenship, resources, and documentation. For those staff identified by the targeted review with errors in these areas, supervisors will provide refresher training on Medicaid policy requirements. Additional targeted reviews will be completed monthly until the deficiencies are corrected. Proposed Completion Date: 1/31/2025 for initial quarterly review 2/28/2025 for refresher training for identified staff 7/31/2025 for additional reviews as needed for identified staff Contact Person: Kathryn Thompson, Economic Benefits Assistant Division Director

View Audit 330686

Finding 512915 (2024-002)

Significant Deficiency 2024

North Idaho College

ID

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking

Finding 2024‐002 Federal Agency Name: Department of Education Assistance Listing Number: 84.268, 84.063, 84.007, 84.033 Program Name: Student Financial Assistance Cluster – Cash Management Finding Summary: During our review of the cash management associated with the match for FSEOG and FWS, it was ...

Finding 2024‐002 Federal Agency Name: Department of Education Assistance Listing Number: 84.268, 84.063, 84.007, 84.033 Program Name: Student Financial Assistance Cluster – Cash Management Finding Summary: During our review of the cash management associated with the match for FSEOG and FWS, it was discovered that the match required by the College of 25 percent, as noted in the federal share of FSEOG and FWS may not exceed 75 percent of total FSEOG and FWS awards, was not performed and there was no waiver to relieve the college of the match requirement. Corrective Action Plan: The College has corrected for the error for the 2024 award year. The drawdown approval process has been modified to include the 25 match calculation with each drawdown request. Additionally, the college will actively confirm whether or not there is a waiver for the federal match every fiscal year. Responsible Individual(s): Vice President for Finance and Business Affairs and Director of Financial Aid.] Anticipated Completion Date: September 2024

View Audit 330678

Finding 512914 (2024-001)

Significant Deficiency 2024

North Idaho College

ID

Special Tests & Provisions Student Financial Aid Significant Deficiency

Finding 2024‐001 Federal Agency Name: Department of Education Assistance Listing Number: 84.268, 84.063, 84.007, 84.033 Program Name: Student Financial Assistance Cluster – Special Tests and Provisions – Return to Title IV Finding Summary: During our review of the Return of Title IV funds, there we...

Finding 2024‐001 Federal Agency Name: Department of Education Assistance Listing Number: 84.268, 84.063, 84.007, 84.033 Program Name: Student Financial Assistance Cluster – Special Tests and Provisions – Return to Title IV Finding Summary: During our review of the Return of Title IV funds, there were five instances out of nineteen in which the Title IV funds to be returned was calculated incorrectly. Corrective Action Plan: The Office of Financial Aid will review and adjust the process for calculation and review of all Return to Title IV calculations. This process will be documented and reviewed periodically to ensure adherence. Responsible Individual(s): Director of Financial Aid] Anticipated Completion Date: January 2025

View Audit 330678

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