Corrective Action Plans

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Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: Th...
Student Financial Assistance Cluster– Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Registrar's Office did note that while nine students were flagged within the audit review, the final report does include an additional 18 students who were not brought to the attention of the Registrar’s Office during the audit. Action taken in response to finding: The Registrar's Office worked with the National Student Clearinghouse to identify new errors with CIP code rejects. We have now updated the curriculum in our SIS to eliminate the error and review the reject report for this specific error. The Registrar's Office will modify the report schedule with the National Student Clearinghouse to every three weeks to assist NSLDS with more time to update their website to align with compliance timelines. The National Student Clearinghouse records show the submission timeline. Name(s) of the contact person(s) responsible for corrective action: Lynn Lundquist Planned completion date for a corrective action plan: The new process started in August 2024
Corrective action plan – Management concurs with this finding. This exception was due to Professional and Continuing Education (PCE) not being part of the withdrawal information workflow. PCE has created an e-form which will be completed by them and submitted to the Office of Financial Aid anytime a...
Corrective action plan – Management concurs with this finding. This exception was due to Professional and Continuing Education (PCE) not being part of the withdrawal information workflow. PCE has created an e-form which will be completed by them and submitted to the Office of Financial Aid anytime a student withdrawals or takes a leave of absence. Management believes these enhancements will be sufficient to prevent future errors. Completion date: August 2024 Persons responsible: Kellie Nehring, Director of Financial Aid and Diana Hannasch-Haag, Director of Retention – Online Degree Programs
Finding 509329 (2024-002)
Significant Deficiency 2024
Recommendation: We recommend that the College review each element of GLBA to ensure compliance with all necessary requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Add sections to the existing policy ...
Recommendation: We recommend that the College review each element of GLBA to ensure compliance with all necessary requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Add sections to the existing policy to correct deficiencies found in the audit Name of the contact person responsible for corrective action: Sean Mays Planned completion date for corrective action plan: December 2024
Finding 509321 (2024-001)
Significant Deficiency 2024
Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A proce...
Recommendation: We recommend the College review its reporting procedures surrounding updating the ECAR to ensure reporting is accurate and completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A process for ensuring all updates to the ECAR are submitted within the proper time frame was in place. Unfortunately, there were delays on the side of the Department of Education that prevented access being granted to all systems within 10 days of Beth Davenport being hired as the Director of Financial Aid. Moving forward, this should not be an issue. Processes are in place to have board updates communicated immediately following board meetings as well as other changes to institutional leadership, third-party servicers, etc. Name of the contact person responsible for corrective action: Beth Davenport Planned completion date for corrective action plan: November 2024
Contact Person Nichole Bristlin, Executive Director. Corrective Action Plan Management plans on adding a signed lease step to the quality control worksheet to ensure signed leases are included in all files. Planned Completion Date for CAP June 30, 2025
Contact Person Nichole Bristlin, Executive Director. Corrective Action Plan Management plans on adding a signed lease step to the quality control worksheet to ensure signed leases are included in all files. Planned Completion Date for CAP June 30, 2025
Independence Housing Authority (IHA) received an audit finding for failing to properly document the reinspection of a failed HQS inspection. During the previous year, IHA had 3 contractors inspecting for HCV and not using the internal software which led to multiple issues including missing documenta...
Independence Housing Authority (IHA) received an audit finding for failing to properly document the reinspection of a failed HQS inspection. During the previous year, IHA had 3 contractors inspecting for HCV and not using the internal software which led to multiple issues including missing documentation. IHA hired a full time, HQS/NSPIRE certified inspector in August 2023 to ensure HQS inspections are completed in a timely manner and within regulation. IHA has also purchased the BOB.AI software which monitors and schedules upcoming initial, reinspection’s, annual and special inspection requests. Inspection letters are generated in this program as well as results/finding items. Inspections spreadsheets have been created for tracking purposes by the HCV Director. The inspector reviews his weekly schedule with the HCV Director for accuracy.
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. C...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Christina Beard, Executive Director, will be responsible to implement this corrective action by March 31, 2025.
View Audit 328914 Questioned Costs: $1
2024-003 Contact Person – Superintendent Brian Clarke Corrective Action Plan – The District will ensure all payroll rates are approved by the Board. Completion Date – November 30th, 2024
2024-003 Contact Person – Superintendent Brian Clarke Corrective Action Plan – The District will ensure all payroll rates are approved by the Board. Completion Date – November 30th, 2024
Item # 2024-02 Indirect Costs Incorrectly Allocated to Federal Award (Significant Deficiency in Internal Control over Federal Major Program) Criteria: Under Uniform Guidance regulations and per the terms of the federal award, the de minimis 10% indirect cost rate for indirect cost allocations must...
Item # 2024-02 Indirect Costs Incorrectly Allocated to Federal Award (Significant Deficiency in Internal Control over Federal Major Program) Criteria: Under Uniform Guidance regulations and per the terms of the federal award, the de minimis 10% indirect cost rate for indirect cost allocations must be used on federal award expenditures. The Guidance also prohibits application of 10% de minimis rate on all subgrants in excess of $25,000 during the period of performance. Condition: Based on the results of our audit testing, we noted indirect costs were allocated incorrectly during the grant period. The total known questioned costs are $1,142. Cause: Management failed to charge indirect costs correctly on the federal subaward during the year ended June 30, 2024. Effect: The effect of the condition was $1,142 in known questioned costs charged to two federal subawards during the year ended June 30, 2024. Auditor’s Recommendation: Management should perform a thorough analysis of the indirect cost allocation to ensure it is reasonable and calculated correctly in accordance with the Uniform Guidance Regulation. Views of Responsible Officials and Planned Corrective Actions: Management understands that indirect expenses incurred on federal awards must be reviewed and allocated appropriately. Management will ensure that it properly allocates indirect costs in accordance with Uniform Guidance and the terms of its federal awards.
View Audit 328788 Questioned Costs: $1
2024-002 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was...
2024-002 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University's Gramm-Leach-Bliley Act Policy did not fully address all of the requirements as described by 16 CFR 314.4. In addition, the application of the comprehensive information security program was not effectively administered by the University during the 2024 year. An updated policy was put into place in February 2024, which addressed several of the deficiencies noted in the existing policy, but not all. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance Corrective Action Plan Summary-The university recently reviewed the Gramm-Leach-Bliley Act Policy and has put in place controls and practices to effectively monitor antl administer the policy. In April 2024, we hired an IT company to help with various campus needs, including data compliance procedures and security measures. The company has been reviewing our current policies and making recommendations to implement appropriate safeguards to keep the university up to date and compliant. We have already installed multi-factor authentication features for our software systems, and there are more updates to come. In July 2024, we received a notice of compliance from the Federal Student Aid regarding our corrective action procedures for the Gramm-Leach-Bliley Act. Anticipated Completion Date- July 1, 2025
2024-005 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University returned funds in an incorrect sequence during the Return to Title IV Funds process upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President fo...
2024-005 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University returned funds in an incorrect sequence during the Return to Title IV Funds process upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University's Vice President of Finance and Financial Aid Administrator recently attended a week-long workshop and received training to complete the R2T4 calculation via COD. The training was received after the infringements and a plan has been adapted to utilize COD for future R2T 4 calculations and sequence. The school calendar has been updated in COD for correct future calculations and sequence. Anticipated Completion Date- July 1, 2025
2024-004 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title ...
2024-004 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect sum of aid disbursed or disbursable to the student when applying the percentage earned in calculating the return to Title IV Funds upon student withdrawal. Name and Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University has enhanced the process of completing return to Title IV calculations by incorporating additional training and workshops provided by the Department of Education. The financial aid office has continued with the implementation of the calendar that displays the attendance days from the first day of school to the last day of school, referring to the school's master calendar. The financial aid office added an extra verification step of written notification from the Registrar's office of beginning and end days for each semester. The return calculations were one day off due to the misinterpretation of the semester's ending date. Anticipated Completion Date- July 1, 2025
View Audit 328701 Questioned Costs: $1
2024-003 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Name and'Title of...
2024-003 Initial Fiscal Year End, 2024 Summary of Finding- During the audit, it was noted that the University used the incorrect number of total days in the payment period or period of enrollment in calculating the percentage of payment period and/or period of enrollment completed. Name and'Title of Responsible Contact Person(s)- Sara Shepherd, Vice President for Finance and Nicole Umphlett, Financial Aid Administrator Corrective Action Plan Summary-The University improved the process for completing return to Title IV calculations by adding in additional training and workshops offered through the Department of Education. The financial aid office continued with the calendar process showing days of attendance from the first day of school to the last using the school's master calendar as a reference. This will be used also as a double check of days when calculating returns. The dates used in the return calculations were off a day due to misreading the ending date of semester. The Financial Aid Administrator verified the beginning and last day of each semester with the Registrar's office in writing. Anticipated Completion Date- July 1, 2025
View Audit 328701 Questioned Costs: $1
Finding 508161 (2024-001)
Significant Deficiency 2024
Need Analysis and Transfer Credits Planned Corrective Action: We updated our report to reflect that all transfer credits are included as part of the total earned credits sent to the third-party processor for awarding. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Fi...
Need Analysis and Transfer Credits Planned Corrective Action: We updated our report to reflect that all transfer credits are included as part of the total earned credits sent to the third-party processor for awarding. Person Responsible for Corrective Action Plan: Donnie Purvis, Director of Financial Services Anticipated Date of Completion: Implemented
Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Human resources manager will collaborate with both a business manager and a grant manager to ensure that employees’ time is being charged to the correct programs and grants in accordance with approved budgets. The hum...
Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Human resources manager will collaborate with both a business manager and a grant manager to ensure that employees’ time is being charged to the correct programs and grants in accordance with approved budgets. The human resource manager will prepare a payroll action form that will list available and applicable funding sources to cover the payroll expenses of an employee. The independent payroll contractor will maintain payroll action notices (PAN) for employees who are covered by multiple funding sources or funding sources other than general fund. In addition, she would update payroll distribution coding in the accounting software to match PAN. She would also match coding on timesheets with coding on PAN and in the accounting software. In case of a discrepancy, she would reach out to a business manager and/or a grant manager on how to resolve it. The Superintendent will review account coding each payroll while performing a review of the payroll check register. In addition, budgeted account codes will be compared to the actual codes being used in payroll on a periodic basis. Proposed Completion Date: Implemented July 1, 2024
Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Human resources manager will collaborate with both a business manager and a grant manager to ensure that employees’ time is being charged to the correct programs and grants in accordance with approved budgets. The hum...
Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Human resources manager will collaborate with both a business manager and a grant manager to ensure that employees’ time is being charged to the correct programs and grants in accordance with approved budgets. The human resource manager will prepare a payroll action form that will list available and applicable funding sources to cover the payroll expenses of an employee. The independent payroll contractor will maintain payroll action notices (PAN) for employees who are covered by multiple funding sources or funding sources other than general fund. In addition, she would update payroll distribution coding in the accounting software to match PAN. She would also match coding on timesheets with coding on PAN and in the accounting software. In case of a discrepancy, she would reach out to a business manager and/or a grant manager on how to resolve it. The Superintendent will review account coding each payroll while performing a review of the payroll check register. In addition, budgeted account codes will be compared to the actual codes being used in payroll on a periodic basis. Proposed Completion Date: Implemented July 1, 2024
Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD hired an experienced and independent contract grants specialist. She is using Outlook to set up reporting reminders to ensure timely submission of reports. In addition, the Business office started using a calenda...
Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD hired an experienced and independent contract grants specialist. She is using Outlook to set up reporting reminders to ensure timely submission of reports. In addition, the Business office started using a calendar developed by ALASBO which addresses all reporting requirements for the school districts in Alaska. Proposed Completion Date: Implemented January 1, 2024
Finding 2024-002 - Uniform Guidance Written Policies and Procedures - Significant Deficiency The District will ensure policies and procedures are developed to make sure contractors are verified that they are not debarred or suspended.
Finding 2024-002 - Uniform Guidance Written Policies and Procedures - Significant Deficiency The District will ensure policies and procedures are developed to make sure contractors are verified that they are not debarred or suspended.
2024-001 Trans-National Crime – Assistance Listing No. 19.705 Recommendation: We recommend African Wildlife Foundation design controls to ensure all first tier awards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Repo...
2024-001 Trans-National Crime – Assistance Listing No. 19.705 Recommendation: We recommend African Wildlife Foundation design controls to ensure all first tier awards in excess of $30,000 are accurately and timely registered with the Federal Funding Accountability and Transparency Act Subaward Reporting System. In addition, AWF should ensure that any subawards are reported within the required time frame. The list of data elements required to be reported for each sub-award in excess of $30,000 include the following: • Subaward date • Subaward DUNS number • Subaward amount • Subaward obligation/action date • Subaward number • Subaward report submission date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have created an account at FSRS.gov and are in the process of filing the FFATA reports for our INL sub-awards. Name(s) of the contact person(s) responsible for corrective action: Richard Holly Planned completion date for corrective action plan: 11/01/2024 If the U.S. Department of State has questions regarding this plan, please call Richard Holly at 202-939-3341
Finding 508025 (2024-001)
Significant Deficiency 2024
Student Financial Assistance Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures to ensure there is a process in place to ensure timely refund of Title IV credit balances. Explanation of d...
Student Financial Assistance Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures to ensure there is a process in place to ensure timely refund of Title IV credit balances. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Student Accounts Office has revised the procedures surrounding all student balances. Balances will be evaluated once a week and a refund will be issued in the next check run. Previously, the Office was conducting this evaluation for the first few weeks of the semester or when a special case occurred. In addition, an error in the report excluded certain balances. The Office has now revised the report to include all students. Name(s) of the contact person(s) responsible for corrective action: Carrie DiEnna Planned completion date for corrective action plan: August 1, 2024
View Audit 328535 Questioned Costs: $1
Eligibility Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University review its current procedures for awarding Title IV funds a...
Eligibility Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.063 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has reviewed its current procedures for awarding Title IV funds and modified edit reports to find Pell-eligible students who had previously been inactivated or not yet awarded for an aid period to be reviewed and awarded accordingly. Name(s) of the contact person(s) responsible for corrective action: James Martin, Director of Financial Aid and Jody Finnegan, Associate Director of Financial Aid Planned completion date for corrective action plan: 09/18/2024
Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.033, 84.268, 84.063, 84.007 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend that the University implement proced...
Special Tests & Provisions Federal Program Title: Student Financial Assistance Cluster Assistance Listing No. 84.033, 84.268, 84.063, 84.007 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend that the University implement procedures to ensure that enrollment data, changes in status and effective dates within NSLDS match the records of the institution and are reported timely. And we recommend that the College implement formal review procedures to document the review process. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: The Office of the Registrar is following the best practices for reporting official withdrawals. We are recording the actual withdrawal date initiated online by the student. We do not have a problem in recording unofficial withdrawals taken from Moodle (as determined by Financial Aid) as long as there is a consensus from Enrollment Management on changing the practice used. I suggest the Financial Aid, Registrar, and Enrollment Management get together to determine the best course of action. Name(s) of the contact person(s) responsible for corrective action: Hala Abou Arraj, Registrar Planned completion date for corrective action plan: 09/01/2024
Cash Management Subrecipient Federal Program Title: Research & Development Cluster Assistance Listing No. 93.859 & 47.074 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its...
Cash Management Subrecipient Federal Program Title: Research & Development Cluster Assistance Listing No. 93.859 & 47.074 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Recommendation: We recommend the University evaluate its procedures and implement an additional control to review and approve the Subrecipient reimbursements timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant accounting staff will follow payment requests through the system to make sure payments are made in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Kirsten Broughton , Director of Grant Accounting. Planned completion date for corrective action plan: Implemented for FY25
Suspension Debarment Federal Program Title: Research & Development Cluster – Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other MattersRecommendation: We recommend the University evaluate its procedures and implement an additional contr...
Suspension Debarment Federal Program Title: Research & Development Cluster – Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other MattersRecommendation: We recommend the University evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU has implemented PaymentWorks, a third-party vendor processing system that does 24-7 suspension and debarment checking. This is conducted on all ISU vendors that onboard through PaymentWorks. All ISU contracts will be processed through Jaggaer, which requires a Banner ID#. All vendors will be initiated through PaymentWorks. Accounts Payable checks sanction alerts in PaymentWorks and follows up with issues. We are also adding the S&D clause to all contracts. Name(s) of the contact person(s) responsible for corrective action: : Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director of Grant Accounting Planned completion date for corrective action plan: July 1, 2024
Finding: During our audit, we noted that certain figures used as inputs to the annual performance report could not be reconciled to supporting documentation and therefore, we were unable to substantiate certain amounts reported to NYSED. The review of the annual performance report was not performed ...
Finding: During our audit, we noted that certain figures used as inputs to the annual performance report could not be reconciled to supporting documentation and therefore, we were unable to substantiate certain amounts reported to NYSED. The review of the annual performance report was not performed at an appropriate level of precision such that the incorrect and/or incomplete information presented would be identified and corrected prior to submission to NYSED. Recommendation: We recommend that the District reevaluate the system of internal control for the review and approval of the annual performance report prior to submission to NYSED, including the reconciliation of amounts included within the support to appropriate supporting documentation. District Response: The District will ensure that, prior to submission to NYSED the annual performance report will be reviewed by an individual other than the preparer and reconciled to the supporting documentation in order to confirm the completeness and accuracy of information reported. In addition, all FS10-F reports (Final Expenditure Reports) were submitted, in compliance and approved by NYSED Grants Finance. Furthermore, our Desk audit was completed and approved by NYSED on October 3, 2024. Mr. Salvatore Carambia, Business Administrator, is the person responsible for the planned corrective action. The completion date for this action is November 30th, 2024.
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