Corrective Action Plans

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The University of Georgia acknowledges the need for increased monitoring over the return to Title IV aid for students withdrawn from the University. UGA has taken immediate corrective action and has filled key staffing vacancies and implemented additional internal controls to monitor and ensure comp...
The University of Georgia acknowledges the need for increased monitoring over the return to Title IV aid for students withdrawn from the University. UGA has taken immediate corrective action and has filled key staffing vacancies and implemented additional internal controls to monitor and ensure compliance. A self-audit of Fall 2024 revealed no non-compliance issues.
To prevent future errors, staff will undergo training to ensure accurate processing of withdrawals that occur after the term has ended. Both official and unofficial withdrawals will be evaluated based on the student's last date of attendance when the withdrawal date is after the end of term. While...
To prevent future errors, staff will undergo training to ensure accurate processing of withdrawals that occur after the term has ended. Both official and unofficial withdrawals will be evaluated based on the student's last date of attendance when the withdrawal date is after the end of term. While the Financial Aid Office (FAO) staff have adhered to the current withdrawal procedures, we recognize the need for an update to address instances when the date a student initiates the official withdrawal process is earlier than when the withdrawal is completed. To address this, we will adopt the date the student begins the withdrawal process as the official withdrawal date, if this date precedes the completion of the withdrawal form. Additionally, we will implement automated and electronic system controls to ensure withdrawals are processed accurately and within the required timelines by monitoring the full withdrawal cycle. The withdrawal policy and administrative procedures documentation will be updated to reflect these changes. Staff will have annual refresher training at the beginning of each academic year. Confirmation of employees, date of training, and training process will be documented.
View Audit 354902 Questioned Costs: $1
Georgia State University (GSU) will ensure all team members are appropriately trained related to the return to title IV process. Procedures have been enhanced to ensure that unearned funds required to be returned to the program due to return to title IV calculations are immediately reconciled and re...
Georgia State University (GSU) will ensure all team members are appropriately trained related to the return to title IV process. Procedures have been enhanced to ensure that unearned funds required to be returned to the program due to return to title IV calculations are immediately reconciled and returned during the required window. GSU has established an Assistant Director over Electronic Processing to carry out these procedures.
Georgia State University (GSU) will ensure all team members are appropriately trained related to the process for locking student financial aid records and completing verifications after the term ends. Additionally, GSU has enhanced monitoring procedures to identify changes to institutional student i...
Georgia State University (GSU) will ensure all team members are appropriately trained related to the process for locking student financial aid records and completing verifications after the term ends. Additionally, GSU has enhanced monitoring procedures to identify changes to institutional student information records after term ends with a verification indicator to ensure these accounts are resolved in a timely manner.
View Audit 354902 Questioned Costs: $1
Effective November 16, 2024, GDOL restructured the Benefit Accuracy Measurement (BAM) unit to strengthen internal controls by incorporating a secondary review process prior to the final review by the supervisor. This process allows the reconciliation of discrepancies and validates the accuracy of th...
Effective November 16, 2024, GDOL restructured the Benefit Accuracy Measurement (BAM) unit to strengthen internal controls by incorporating a secondary review process prior to the final review by the supervisor. This process allows the reconciliation of discrepancies and validates the accuracy of the case findings prior to the supervisory review. If the reviewer identifies questionable items during the review, the case is returned to the auditor for corrections and updates. Once completed, it is returned back to the reviewer for an additional review, sign-off, and then submission to the supervisor for review and closure. Beginning April 2025, an initiative will be implemented to train staff to perform quality checks. Staff will review a sample of cases completed by other auditors in the previous quarter and provide feedback. This plan is being established to posture staff to supplement gaps in resources if the need arises and address challenges, such as, attrition. This allows staff to effectively fulfill the responsibility of reviewing cases and preparing them for official signoff in a timely manner. Summary: GDOL greatly appreciates the feedback and recommendations and has and will continue to take appropriate measures to ensure the established BAM procedures are followed.
After the September 2023 quarter, controls were put in place to ensure accurate Federal quarterly reports. These controls included preparing the report based on our accounting records, e.g. the general ledger. Another control is that the Chief Financial Officer or her designee reviews all reports an...
After the September 2023 quarter, controls were put in place to ensure accurate Federal quarterly reports. These controls included preparing the report based on our accounting records, e.g. the general ledger. Another control is that the Chief Financial Officer or her designee reviews all reports and compares them to the general ledger prior to signature, approval and our submission to the grantor. Furthermore, periodic reviews by program fiscal staff during the performance period take place to closely monitor activity. GDOL will continue to follow the updated procedures and internal controls. As we transition to GA@Work, the system itself will control overspending and provide alerts.
Corrective Action: LSA is committed to strengthening our policies and procedures concerning the management of case files. We will collaborate closely with our Managing Attorneys to ensure that all compliance requirements are met effectively. Regarding the failure to disclose an affirmative filing un...
Corrective Action: LSA is committed to strengthening our policies and procedures concerning the management of case files. We will collaborate closely with our Managing Attorneys to ensure that all compliance requirements are met effectively. Regarding the failure to disclose an affirmative filing under 64 CFR 1644 - LSA does acknowledge that in two cases (from 2022 and 2023), one employee who was new to LSA failed to enter the case information into Legal Server in a timely manner which led to it not being reported in our report. This issue was noted by the individuals Managing Attorney approximately one year ago and measures were put in place at that time to ensure that the information was entered timely. Additionally, the staff person was trained pursuant to the training in our Corrective Action plan last year regarding 1644. These two incidents predate that training. LSA will continue to monitor 1644 information in our system to ensure it is entered timely. Our goal is to ensure full compliance moving forward.
Finding 556016 (2024-002)
Significant Deficiency 2024
Recommendation: We recommend that management implement a control to ensure complete documentation is maintained for all cases that require retainer agreement. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: Our Deput...
Recommendation: We recommend that management implement a control to ensure complete documentation is maintained for all cases that require retainer agreement. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: Our Deputy Director/General Counsel contacted the person who had failed to sign the retainer that was missing the staff signature to remind them of that requirement. She also held a training on LSC requirements in Q1 2025 in which she reminded staff of the retainer requirement. Name of the contact person responsible for corrective action: Teresa Sullivan, Deputy Director / General Counsel Planned completion date for corrective action plan: Already implemented
Finding 556015 (2024-001)
Significant Deficiency 2024
Recommendation: We recommend that management implement a control to review PAI time entries to ensure they are accurate. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: In 2024, but after employees logged the two erro...
Recommendation: We recommend that management implement a control to review PAI time entries to ensure they are accurate. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: In 2024, but after employees logged the two erroneous PAI entries, we implemented a new PAI time entry system in LegalServer. Employees must now choose the nature of the PAI involvement when they log the time, which would have avoided both of the two erroneous entries, had that been in place. Additionally, our Deputy Director/General Counsel provided an LSC regulations training in Q1 2025 to remind employees of LSC regulations, including the regulation governing PAI time. Name of the contact person responsible for corrective action: Teresa Sullivan, Deputy Director / General Counsel Planned completion date for corrective action plan: Already implemented
The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the transportation department reviewing bus logs. The District will assign someone in the District office to review all logs. Shannon Grindell Ongoing
The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the transportation department reviewing bus logs. The District will assign someone in the District office to review all logs. Shannon Grindell Ongoing
The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service department working with the claims. The District will assign someone in the District office to review all claims. Shannon Grindell, Susan Mayer Ongoing
The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service department working with the claims. The District will assign someone in the District office to review all claims. Shannon Grindell, Susan Mayer Ongoing
The Executive Director has implemented procedures for the procurement of an auditor to ensure the Financia Data Schedule is filed within nine months after the conclusion of the fiscal year. Name of Responsible Person: Tami Lucia, Executive Director Implementation date: September 2024
The Executive Director has implemented procedures for the procurement of an auditor to ensure the Financia Data Schedule is filed within nine months after the conclusion of the fiscal year. Name of Responsible Person: Tami Lucia, Executive Director Implementation date: September 2024
RHA has put in place comprehensive new procedures and controls for all the staff members, including Clerks, Housing Assistants, Housing Coordinators and Project Managers, concerning the management of the waiting list process. As of September 2024m a new waiting list will be generating following each...
RHA has put in place comprehensive new procedures and controls for all the staff members, including Clerks, Housing Assistants, Housing Coordinators and Project Managers, concerning the management of the waiting list process. As of September 2024m a new waiting list will be generating following each new move-in, and the previous waiting list will be appropriately filed and preserved. Name of Responsible Person: Entire Admin Staff lmplementatio_n Date: September 2024
All federal food commodities received will be entered into the SMF QuickBooks system and reported to the Arkansas Department of Education (ADE) within 48 hours of delivery by the Operations Manager or his assistant. All federal food receipts will be verified by a secondary employee monthly to ensure...
All federal food commodities received will be entered into the SMF QuickBooks system and reported to the Arkansas Department of Education (ADE) within 48 hours of delivery by the Operations Manager or his assistant. All federal food receipts will be verified by a secondary employee monthly to ensure ADE has received and properly processed the submission into their system. Any discrepancies will be discussed and corrected as necessary. Harvest will perform an inventory count quarterly and adjust inventory amounts as needed in the SMF QuickBooks system.
CT Energy Assistance Program– Assistance Listing No. 93.568 Recommendation: We recommend Alliance for Community Empowerment, Inc. design controls to ensure an adequate review process is in place to review the period of costs incurred to ensure costs are charged to grants in the proper period. Action...
CT Energy Assistance Program– Assistance Listing No. 93.568 Recommendation: We recommend Alliance for Community Empowerment, Inc. design controls to ensure an adequate review process is in place to review the period of costs incurred to ensure costs are charged to grants in the proper period. Action taken in response to finding: All expenditures will be reviewed and recorded in the proper period of performance. The correction was put into place during the audit and all expenditures have been reviewed during entry and at the point of signature from the Finance Director. Name of the contact person responsible for corrective action: Indi Hayes, Finance Director Planned completion date for corrective action plan: March 21, 2025
View Audit 354453 Questioned Costs: $1
Management has reviewed the audit finding and acknowledges the delay in depositing surplus cash. Management was under the impression that the surplus cash was going to be used for the reduction of a future HAP payment. Management believes this was an isolated incident and has taken corrective action...
Management has reviewed the audit finding and acknowledges the delay in depositing surplus cash. Management was under the impression that the surplus cash was going to be used for the reduction of a future HAP payment. Management believes this was an isolated incident and has taken corrective action by reinforcing internal procedures to ensure timely deposits in the future. Additional monitoring measures have been implemented to prevent recurrence.
Finding 555487 (2024-015)
Significant Deficiency 2024
Views of Responsible Officials and Planned Corrective Action This is completed and will be completed again in June 2025. Finding resolution timeline: No later than June 2025. Designation of employee position responsible for meeting this deadline: Andrea Montoya, Deputy County Manager
Views of Responsible Officials and Planned Corrective Action This is completed and will be completed again in June 2025. Finding resolution timeline: No later than June 2025. Designation of employee position responsible for meeting this deadline: Andrea Montoya, Deputy County Manager
Finding # 2024-004 Type: Significant deficiency over eligibility A.L. 14.218 U.S. Department of Housing and Urban Development Significant Deficiency Case file intake forms reviewed did not have documentation of required eligibility requirements for 7 of 35 case files selected. Corrective Action...
Finding # 2024-004 Type: Significant deficiency over eligibility A.L. 14.218 U.S. Department of Housing and Urban Development Significant Deficiency Case file intake forms reviewed did not have documentation of required eligibility requirements for 7 of 35 case files selected. Corrective Action: We were able to substantiate the eligibility of all participants however we agree improvement is needed in providing additional training for onboarding staff on eligibility criteria as well as ensuring onboarding forms are complete and accurate. We will also implement a formal manager review and approval of intake forms which includes validating eligibility criteria have been met. Anticipated Completion Date May 30, 2025
Procedures for maintaining accurate accounts receivable records will be reinforced, including periodic review. Beginning June 1, 2025, we will implement steps and procedures to eliminate the tardiness of Data Collection in Federal Audit Clearinghouse.
Procedures for maintaining accurate accounts receivable records will be reinforced, including periodic review. Beginning June 1, 2025, we will implement steps and procedures to eliminate the tardiness of Data Collection in Federal Audit Clearinghouse.
Finding 555300 (2024-001)
Significant Deficiency 2024
Finding Number 2024-001: Monitoring of Funds Passed to Subrecipient Federal Program ALN: 93.575 Corrective Action Plan: Zero to Five Montana has implemented updated policies and procedures to ensure proper execution and documentation of subrecipient contracts and payments. All contracts are now proc...
Finding Number 2024-001: Monitoring of Funds Passed to Subrecipient Federal Program ALN: 93.575 Corrective Action Plan: Zero to Five Montana has implemented updated policies and procedures to ensure proper execution and documentation of subrecipient contracts and payments. All contracts are now processed and signed via an electronic signing service (e.g., DocuSign) by the Executive Director, with copies securely retained. Prior to disbursing funds, subrecipients with executed contracts are set up as vendors in the expense management system. The subrecipient must complete their vendor profiles and submit tax documentation. Payments are supported by an invoice that includes payment details, expense codes, and grant assignments (if applicable), and must be reviewed and approved by the Program and Operations Directors to confirm all documentation and compliance steps are met. Staff will be trained on these procedures by April 14, 2025, and quarterly audits will be conducted to monitor adherence, with findings reported to leadership and the governing board. Contact Person Responsible for Corrective Action: Caitlin Jensen, Executive Director Anticipated Completion Date: April 14, 2025
Spartanburg County First Steps (SCFS) management acknowledges its responsibility for complying with all applicable state and federal reporting requirements. SCFS maintains a comprehensive fiscal policies and procedures manual that outlines the responsibilities and processes necessary to ensure compl...
Spartanburg County First Steps (SCFS) management acknowledges its responsibility for complying with all applicable state and federal reporting requirements. SCFS maintains a comprehensive fiscal policies and procedures manual that outlines the responsibilities and processes necessary to ensure compliance with all reporting obligations. The late submission of certain federal reports for the 2023-2024 program year was primarily due to challenges associated with the agency's financial management system, Blackbaud. Specifically, the system generated extended wait times for necessary reports, significantly impacting the agency's ability to meet required deadlines. Over the past six months, SCFS has conducted an extensive evaluation of the Blackbaud system and determined that it does not adequately meet the operational needs of SC First Steps offices across the state. As a result, an emergency procurement process has been initiated to procure a new financial management system that will better support timely and accurate reporting. Spartanburg County First Steps is committed to ensuring all future state and federal reporting requirements are completed and submitted accurately and within required deadlines.
Finding 555196 (2024-002)
Significant Deficiency 2024
Finding 2024-002 Corrective Action Plan The College reassigned the duties within its business office to ensure remittances to students or parent borrowers of credit balances are executed in accordance with the timeline mandated by the U.S. Department of Education. Gratz College notes that this was ...
Finding 2024-002 Corrective Action Plan The College reassigned the duties within its business office to ensure remittances to students or parent borrowers of credit balances are executed in accordance with the timeline mandated by the U.S. Department of Education. Gratz College notes that this was the only instance of noncompliance and resulted from turnover in Gratz College’s business office staff. Anticipated Completion Date The corrective action plan was completed June 1, 2024 Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities Ross Holgado – Manager of Financial Reporting Karen West – Senior Accounting Associate and Coordinator of Student Billing
2024-002 – Enrollment Reporting (Significant Deficiency) Department of Education, SFA Cluster; Compliance Requirement Affected – Special Tests and Provisions Condition: The University did not report student enrollment data to the National Student Clearinghouse accurately and within minimum required ...
2024-002 – Enrollment Reporting (Significant Deficiency) Department of Education, SFA Cluster; Compliance Requirement Affected – Special Tests and Provisions Condition: The University did not report student enrollment data to the National Student Clearinghouse accurately and within minimum required timeframe. Criteria: Based on requirements set forth by 34 CFR 685.309(b)(2), the University is responsible for notifying the National Student Loan Data System (NSLDS) to changes to student’s enrollment data within minimum required timeframes. Cause: The University does not have adequate procedures in place to ensure changes in students’ enrollment statuses are identified and reported in a timely manner. Effect: Enrollment data was not reported timely or accurately to the Department of Education thus, the Department could not properly service the student’s loans. The accuracy of Title IV student loan records depends heavily on the accuracy of the enrollment information reported by institutions. Context: A sample of nine official and unofficial student withdrawals was selected for audit from a population of 63. The test found three student withdrawals that were not in compliance with timely enrollment reporting in NSLDS, the enrollment status for one student was not updated after the student was no longer enrolled on at least a half-time basis, and one student’s enrollment status date reported to NSLDS did not agree to date of withdraw reported on the R2T4 form. Repeat Finding: No. Recommendation: We recommend that the University put procedures in place to ensure that student enrollment statuses are updated in a timely manner. Management Response: The University has modified its withdrawal procedures and instructions related to the requirements set forth by 34 CFR 685.309(b)(2). Related to the findings above, due to staffing turnover, the appropriate test of controls needed to identify changes in a student’s enrollment status was not run in a timely manner. Going forward, the University has informed related staff that the aforementioned test of controls needs to be run at the end of each semester, and upon completion, staff must notify the NSLDS within the required timeframe. If the Federal Audit Clearinghouse has questions regarding this plan, please call Brad Sheriff, PhD, MBA, CMA, Interim Chief Financial Officer at (540) 887-7285. Brad Sheriff, PhD, MBA, CMA, Interim Chief Financial Officer, Mary Baldwin University, 540-887-7285
2024-001 – Return of Title IV Funds (Significant Deficiency)Department of Education, SFA Cluster; Compliance Requirement Affected – Special Tests and Provisions Condition: Return of Title IV funds occurred untimely for three students, exceeding 45 days as required, when considering the University’s ...
2024-001 – Return of Title IV Funds (Significant Deficiency)Department of Education, SFA Cluster; Compliance Requirement Affected – Special Tests and Provisions Condition: Return of Title IV funds occurred untimely for three students, exceeding 45 days as required, when considering the University’s date of determination as reported on R2T4 forms. Criteria: Returns of Title IV funds are required to be deposited or transferred into the SFA account or electronic funds transfers initiated to the Department of Education as soon as possible, but no later than 45 days after the date the institution determines that the student withdrew in accordance with 34 CFR 668.173(b). Cause: The University does not have adequate procedures in place to ensure students’ Title IV funds are returned timely. R2T4 forms improperly reported the date of determination the same as the student withdraw date. Effect: The University failed to return Title IV funds to the Department of Education within 45 days of the students’ date of determination as reported on the R2T4 forms. Context: A sample of nine official and unofficial student withdrawals was selected for audit from a population of 63. The test found three student withdrawals that were not in compliance with timely return of funds. Repeat Finding: No. Recommendation: We recommend that the University implement procedures to ensure that R2T4 forms are filed timely and properly reflect the University’s date of determination for all student withdrawals. Management Response: The University concedes that the R2T4 forms improperly reported the date of determination as the same date reported for the student’s date of withdrawal and the University has modified its withdrawal procedures and processes to reflect separate dates when necessary for date of determination and date of withdrawal. Instructions related to R2T4 requirements and timeliness of return of funds will be triggered from the appropriate date of determination. Related to the findings above, the University failed to accurately report the date of determination on R2T4 documentation, causing the return of funds to be out of the window for timely return. Although the funds were returned in a timely manner, the recordkeeping of the determination date was not documented properly. The University has since clarified for staff the importance of this documentation and change in process. Additionally, the university has identified the appropriate test of controls needed to accurately identify the student withdrawal date. This test of controls will be run at the end of each semester, and upon completion, the date the report is run will be used as the correct date of determination. If the Federal Audit Clearinghouse has questions regarding this plan, please call Brad Sheriff, PhD, MBA, CMA, Interim Chief Financial Officer at (540) 887-7285. Brad Sheriff, PhD, MBA, CMA, Interim Chief Financial Officer, Mary Baldwin University, 540-887-7285
Finding: 2024-002 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number(s): 93.423 Program Name: 1332 State Innovation Waivers Finding Summary: Recipients of federal funds must submit financial reports as required by the Federal award. Reports submitted annually...
Finding: 2024-002 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number(s): 93.423 Program Name: 1332 State Innovation Waivers Finding Summary: Recipients of federal funds must submit financial reports as required by the Federal award. Reports submitted annually by the recipient must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period, in accordance with CFR § 200.328(c). The Association’s existing controls over their reporting processes, to ensure reports were submitted timely, were not functioning in such a way that ensured reports were submitted on time. Responsible Individuals: Christopher E Howard, General Counsel and Secretary Corrective Action Plan: Management has established a multi-tier calendar control to notify them when reports are due in order to ensure timely filing of all reports. Anticipated Completion Date: Completed April 9, 2025.
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