Corrective Action Plans

Finding 537638 (2024-003)

Significant Deficiency 2024

PA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

The PHA must inspect the unit leased to a family at least bi-annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR §§982.405, 983.103)). Additionally, for units under HAP ...

The PHA must inspect the unit leased to a family at least bi-annually to determine if the unit meets Housing Quality Standards (HQS) and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR §§982.405, 983.103)). Additionally, for units under HAP contract that fail to meet HQS, the PHA must require the owner to correct any life threatening HQS deficiencies within 24 hours after the inspections and all other HQS deficiencies within 30 calendar days or within a specified PHA-approved extension. If the owner does not correct the cited HQS deficiencies within the specified correction period, the PHA must stop (abate) HAPs beginning no later than the first of the month following the specified correction period or must terminate the HAP contract. The owner is not responsible for a breach of HQS as a result of the family’s failure to pay for utilities for which the family is responsible under the lease or for tenant damage. For family-caused defects, if the family does not correct the cited HQS deficiencies within the specified correction period, the PHA must take prompt and vigorous action to enforce the family obligations (24 CFR sections 982.158(d) and 982.404). During our audit, we identified two (2) failed HQS with life-threating fails that did not receive a pass within the required 24-hour time frame. The HQS population had 135 failed inspections. We selected a sample of 15 inspection and identified of those 15 reviewed 2 did not obtain a re-inspection pass within the Criteria noted above and no rent abatement process was enforced on landlord. Recommendations We suggest the Authority properly oversee compliance with regulations and enforce rent abatements if necessary to adherence to federal compliance requirements. Corrective Action Plan Staff have implemented a new approach to addressing compliance issues immediately and notifying the Deputy Executive Director to enforce abatements. Staff are also required to do additional annual training.

View Audit 348917

Finding 537628 (2024-001)

Significant Deficiency 2024

Lawrence Union Free School District

NY

Procurement, Suspension & Debarment Cash Management Significant Deficiency § 200.303

Significant Deficiency 2024-001. Procurement United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondar...

Significant Deficiency 2024-001. Procurement United States Department of Education, passed through New York State Department of Education Education Stabilization Fund COVID-19: Elementary and Secondary School Emergency Relief Fund ALN: 84.425D COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief ALN: 84.425U COVID-19: American Rescue Plan – Elementary and Secondary School Emergency Relief – Homeless Youth and Children ALN: 84.425W Condition: The District has not updated its existing policies and written procedures to conform to Uniform Guidance requirements. Planned Corrective Action: The District’s Assistant Superintendent for Business and Operations will work on updating all policies and procedures relating to U.S. Office of Management and Budget Uniform Guidance to ensure that District policies are in compliance with these guidelines. Responsible Contact Person: Jeremy Feder Assistant Superintendent for Business and Operations Lawrence Union Free School District 2 Reilly Road Cedarhurst, NY 11516 Anticipated completion date: June 30, 2025.

View Audit 348909

Finding 537613 (2024-002)

Significant Deficiency 2024

Missouri Valley College

MO

Student Financial Aid Significant Deficiency

2024-002 Plan: As of 03/20/2025 this is complete. Objective: Ensure that the Return to Title IV calendar is set up correctly. In order to address the original setup of the Return to Title IV calendar that was done with Colleague specialists in the original setup, we now confirm that the calendar is ...

2024-002 Plan: As of 03/20/2025 this is complete. Objective: Ensure that the Return to Title IV calendar is set up correctly. In order to address the original setup of the Return to Title IV calendar that was done with Colleague specialists in the original setup, we now confirm that the calendar is now correctly established and that the previous issues have been resolved. Initially, the calendar was impacted by the inclusion of four federal holidays, which led to inaccuracies. To rectify this, we conducted thorough research and collaborated closely with Ellucian support to devise a robust annual setup plan that will prevent the recurrence of such errors in the future. Moving forward, we have instituted a proactive approach in which we will meticulously review and manually count the calendar each year prior to the start of the academic year. This ensures that all holidays and relevant dates are accurately reflected in the calendar to align with federal guidelines, effectively mitigating any potential disruptions. Through these measures, we aim to maintain compliance and enhance the overall integrity of our Return to Title IV processes. Objective: Ensure that the Return to Title IV funds are returned within the 45 day timeline. lnorder to address the timely return of funds within the 45-day federal timeframe, we acknowledge that this was our first year utilizing a new system, which presented a learning curve for our team. To address this challenge, we partnered with the Ellucian team to implement an automated notification system that triggers alerts at the 30-day mark whenever a Return to Title IV (R2T 4) calculation has been performed but the associated funds have not yet been returned or transmitted for return. This proactive measure is designed to enhance our operational efficiency and ensure compliance with federal regulations. By enabling timely notifications, we can better maintain the integrity of federal policies and the R2T 4 process itself, allowing our staff to take appropriate action and ensure that funds are returned promptly. Furthermore, we will conduct periodic reviews of this system and its effectiveness to identify any additional improvements, fostering ongoing compliance and strengthening our financial processes in future academic years.

View Audit 348884

Finding 537607 (2024-001)

Significant Deficiency 2024

Clarkstown Central School District

NY

Allowable Costs / Cost Principles Significant Deficiency

Re: 2023-24 Single Audit Response and Corrective Action Plan The Clarkstown Central School District (the 'District') has received R.S. Abrams' Single Audit report dated March 21, 2025. This document serves as the District's Single Audit Response and Corrective Action Plan. The Board of Education an...

Re: 2023-24 Single Audit Response and Corrective Action Plan The Clarkstown Central School District (the 'District') has received R.S. Abrams' Single Audit report dated March 21, 2025. This document serves as the District's Single Audit Response and Corrective Action Plan. The Board of Education and the District's Administration extend a thank you to R.S Abrams for their time and effort devoted to the detailed examination of internal controls. The District accepts the recommendation as noted and has instituted the attached Corrective Action Plan. The District strongly supports the audit process and welcomes all efforts to ensure that District internal controls are in alignment with best practices. #1 Recommendation: Allowable Cost principles - payroll "During our current year audit, we noted that although the District ultimately obtained Payroll Certification Forms from the employees funded through these federal funds as per District policy , they did not comply with their written procedures regarding the timeliness of obtaining signed Payroll Certification Forms from employees whose salaries were funded through federal funds." Corrective Action Plan The District agrees that in the 2023-24 grant year, the Payroll Certification Forms were not prepared and processed in a timely manner. This was due, in part, to staffing issues being experienced by the Accounting Department. To ensure timely preparation in the future , the District will schedule distribution of certification forms no later than November 30th. Mr. William Molloy, Deputy Treasurer , will compile the information and provide it to Ms. Bridgette Dunmire, Senior Clerk, no later than November 15th. Ms. Dunmire will prepare the forms , based on the data provided, and submit them to Mr. Molloy for review. Certification forms will be distributed electronically by Ms. Dunmire no later than November 30th. This process will be effective beginning with 2024-25 grant year.

View Audit 348878

Finding 537596 (2024-002)

Significant Deficiency 2024

University System of New Hampshire

NH

Reporting Student Financial Aid Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement ...

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will update enrollment status reporting procedures and provide training to staff to ensure changes are reported to NSLDS in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Cathy Mullins, Director of Financial Aid and Scholarships, Keene State College Planned completion date for corrective action plan: March 31, 2025

View Audit 348873

Finding 537591 (2024-001)

Significant Deficiency 2024

University System of New Hampshire

NH

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the College put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit find...

Student Financial Assistance Cluster – Assistance Listing Numbers 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: We recommend that the College put a process in place to refund student credit balances that arose from federal funds within 14 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will update credit balance reporting and monitoring procedures and provide training to staff to ensure refunds are done in a timely manner. Name(s) of the contact person(s) responsible for corrective action: Cathy Mullins, Director of Financial Aid and Scholarships. Keene State College Planned completion date for corrective action plan: April 30, 2025

View Audit 348873

Finding 537566 (2024-002)

Significant Deficiency 2024

Seniorsplus

ME

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties § 200.303

Management is committed to compliance in accordance with all grant agreements and will work to formally document the Agency’s internal controls over Federal and State awards. Additional training will be provided as needed to prevent future findings.

View Audit 348846

Finding 537554 (2024-001)

Significant Deficiency 2024

Town of East Greenwich Housing Authority

RI

HUD Housing Programs Special Tests & Provisions Significant Deficiency

2024-001 General Depository Agreements a. Corrective Action-It was found that the Depository Agreement on file with EGHA and Citizens Bank going back to 2010 was never fully executed. A new HUD 51999 was completed and signed by the EGHA Executive Director and forwarded to Citizens for signatures. On...

2024-001 General Depository Agreements a. Corrective Action-It was found that the Depository Agreement on file with EGHA and Citizens Bank going back to 2010 was never fully executed. A new HUD 51999 was completed and signed by the EGHA Executive Director and forwarded to Citizens for signatures. Once completed, it will be forwarded to HUD for their signature.

View Audit 348840

Finding 537552 (2024-002)

Significant Deficiency 2024

Winona-Montgomery Consolidated School District

MS

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Subrecipient Monitoring

2024-002 a. Name of Contact Person Responsible for Corrective Action: Lynea Watson – Business Manager b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, including compliance with all ...

2024-002 a. Name of Contact Person Responsible for Corrective Action: Lynea Watson – Business Manager b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, including compliance with all federal grant requirements. c. Anticipated Completion Date: Immediately.

View Audit 348831

Finding 537546 (2024-001)

Significant Deficiency 2024

Integral Care

TX

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.1 § 200.414

Corrective Action Plan Finding 2024-001 Finding Summary: The Center did not exclude charges for patient care when calculating modified total direct costs (MTDC) in accordance with Uniform Guidance and TxGMS and thus the indirect rate used in calculating the indirect amount charged to the grant was n...

Corrective Action Plan Finding 2024-001 Finding Summary: The Center did not exclude charges for patient care when calculating modified total direct costs (MTDC) in accordance with Uniform Guidance and TxGMS and thus the indirect rate used in calculating the indirect amount charged to the grant was not consistently accurate. Corrective Action Plan: The Center has historically calculated the indirect amount using the same methodology over time. Given the small volume of patient receipts, the impact on the total indirect amount is minor. We believe that had we modified our calculations, we would have had enough modified total direct costs to cover the change in the calculation. The Center will modify all future calculations to ensure alignment. We will also review the fiscal year covered under this audit to understand what the impact of the change would have been on the split between cost types. Note that since we are midway through our next fiscal year, and we consider the differences minor, we have determined that we will correct for any future reimbursement requests, but will not modify prior reimbursement requests. Similarly, we will conduct a review of that fiscal year to determine the impact of the change and verify it is not significant. Responsible Individuals: Rusty Taylor, CFO Joe Carrington, Director of Financial Planning and Analysis Anticipated Completion Date: August 2025

View Audit 348829 Questioned Costs: $1

Finding 537540 (2024-002)

Significant Deficiency 2024

Jefferson County Industrial Development Agency

NY

Subrecipient Monitoring Significant Deficiency

Views of Responsible Officials and Planned Corrective Actions: We acknowledge the validity of this finding and offer the following explanation. While we recognized the Agency’s role as a subrecipient, we did not fully understand the guidelines for distinguishing between a “contractor” and a “subreci...

Views of Responsible Officials and Planned Corrective Actions: We acknowledge the validity of this finding and offer the following explanation. While we recognized the Agency’s role as a subrecipient, we did not fully understand the guidelines for distinguishing between a “contractor” and a “subrecipient” when making a subaward to another organization. However, through a thorough discussion and assessment of the guidelines with the auditors, along with a joint review of the GSA-CX-1.8: Subrecipient and Contractor Determination Form, we have gained clarity on the proper process for making accurate determinations in future subawards. Corrective Action: For future grant awards, Agency staff will review the use of funds in accordance with federal guidelines to determine whether the recipient qualifies as a subrecipient or a contractor. Additionally, the Agency has taken steps to notify the organization of their subrecipient status and their obligation to conduct a Single Audit in compliance with Government Accounting Standards and Uniform Guidance requirements.

View Audit 348822

Finding 537537 (2024-001)

Significant Deficiency 2024

Town of Boylston

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2025 ...

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2025 Contact: April Steward, Town Administrator

View Audit 348815

Finding 537528 (2024-003)

Significant Deficiency 2024

Housing Authority of Prince George's County

MD

HUD Housing Programs Significant Deficiency Special Tests & Provisions

2024-003 Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their process and internal controls for rent reasonableness to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: T...

2024-003 Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their process and internal controls for rent reasonableness to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAPGC has implemented a new Rent Reasonableness software that provides a user-friendly method for ensuring Rent Reasonableness compliance. HAPGC has hired a new Voucher Program Director. The new Director will strictly enforce current program policy which requires Recertification and Intake Specialists to attach all required documentation within 3 business days of receipt to the program participant’s electronic file. Additionally, Program Managers, as well as Recertification and Intake Specialists, will be held accountable through disciplinary action when corrective actions noted through the quality control review process are not corrected within 15 business days. Finally, all HCV staff persons will be required to take the Housing Choice Voucher Certification class annually to ensure proper training and adequate understanding of the voucher program rules. Name(s) of the contact person(s) responsible for corrective action: Carolyn Floyd, Housing Choice Voucher Program, Director cefloyd@co.pg.md.us. Planned completion date for corrective action plan: December 31, 2025.

View Audit 348795

Finding 537527 (2024-002)

Significant Deficiency 2024

Housing Authority of Prince George's County

MD

HUD Housing Programs Eligibility Significant Deficiency

2024-002 Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their process and internal controls for new tenants to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There is...

2024-002 Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their process and internal controls for new tenants to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAPGC has hired a new Voucher Program Director. The new Director will strictly enforce current program policy which requires Recertification and Intake Specialists to attach all required documentation within 3 business days of receipt to the program participant’s electronic file. Additionally, Program Managers, as well as Recertification and Intake Specialists, will be held accountable through disciplinary action when corrective actions noted through the quality control review process are not corrected within 15 business days. Finally, all HCV staff persons will be required to take the Housing Choice Voucher Certification class annually to ensure proper training and adequate understanding of the voucher program rules. Name(s) of the contact person(s) responsible for corrective action: Carolyn Floyd, Housing Choice Voucher Program, Director cefloyd@co.pg.md.us. Planned completion date for corrective action plan: December 31, 2025.

View Audit 348795

Finding 537526 (2024-001)

Significant Deficiency 2024

Housing Authority of Prince George's County

MD

HUD Housing Programs Eligibility Significant Deficiency

2024-001 Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There i...

2024-001 Housing Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review their process and internal controls over eligibility to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAPGC has hired a new Voucher Program Director. The new Director will strictly enforce current program policy which requires Recertification and Intake Specialists to attach all required documentation within 3 business days of receipt to the program participant’s electronic file. Additionally, Program Managers, as well as Recertification and Intake Specialists, will be held accountable through disciplinary action when corrective actions noted through the quality control review process are not corrected within 15 business days. Finally, all HCV staff persons will be required to take the Housing Choice Voucher Certification class annually to ensure proper training and adequate understanding of the voucher program rules. Name(s) of the contact person(s) responsible for corrective action: Carolyn Floyd, Housing Choice Voucher Program, Director cefloyd@co.pg.md.us. Planned completion date for corrective action plan: December 31, 2025.

View Audit 348795

Finding 537488 (2024-003)

Significant Deficiency 2024

City and Borough of Juneau, Alaska

AK

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.306

FEDERAL AWARD FINDING Finding: 2024-003 Significant Deficiency in Internal Controls over Compliance and Compliance – Setup and Monitoring of Reporting and Match Name of Contact Person: Angie Flick, Director of Finance Corrective Action: The accountants will be going through additional training on se...

FEDERAL AWARD FINDING Finding: 2024-003 Significant Deficiency in Internal Controls over Compliance and Compliance – Setup and Monitoring of Reporting and Match Name of Contact Person: Angie Flick, Director of Finance Corrective Action: The accountants will be going through additional training on setting up grants in the system and how to reconcile them. CBJ will also be completing a grant reconciliation process quarterly instead of annually. This will act both as a control as well as an opportunity to make timely corrections in the case of error. Proposed Completion Date: September 30, 2025

View Audit 348728

Finding 537486 (2024-003)

Significant Deficiency 2024

Town of Manchester

MD

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility § 200.214 § 200.303

DEPARTMENT OF TREASURY 2024-003 Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend management ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls ...

DEPARTMENT OF TREASURY 2024-003 Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend management ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to issuance of the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will ensure all new vendors will sign a suspension and debarment agreement prior to any payments being made. Name of the contact person responsible for corrective action: Kelly Baldwin, Director of Finance Planned completion date for corrective action plan: March 31, 2025 If the Cognizant or Oversight Agency has questions regarding this plan, please call Kelly Baldwin, Director of Finance at 410-239-3200.

View Audit 348723

Finding 537483 (2024-001)

Significant Deficiency 2024

Kyrene Elementary School District No. 28

AZ

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs

Findings and Questioned Costs Related to Federal Awards Finding Number: 2024‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Brian Lockery, Director of Finance Anticipated Completion Date: The finding was corrected...

Findings and Questioned Costs Related to Federal Awards Finding Number: 2024‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Brian Lockery, Director of Finance Anticipated Completion Date: The finding was corrected as of February 18, 2025. Planned Corrective Action: District staff took the following steps to immediately remedy this finding:  Entered and approved a journal entry in the FY24 general ledger to correct the indirect cost transfer out of Fund 510 and into Fund 570 as authorized under the program.  Submitted to ADE a request to open a 15‐915 data correction to submit a revised FY24 Annual Financial Report (AFR), Food Service AFR and School by School (AFR).  ADE opened the 15‐915 window, and Kyrene submitted all three revised AFRs.  ADE processed and approved all three AFRs.  Kyrene submitted all three revised AFRs to its governing board for approval on March 25, 2025.  FY25 opening fund balances were additionally corrected to reflect the changes approved in the revised AFRs. Kyrene remedied this finding as of February 18, 2025. Kyrene now employs a new, revised calculator tool which limits the amount of the food service contract expenses to $25,000 maximum annually. This worksheet will be used to calculate the maximum allowable indirect cost rate transfer from Fund 510 Food Services to Fund 570 Indirect Costs.

View Audit 348721 Questioned Costs: $1

Finding 537462 (2024-003)

Significant Deficiency 2024

Fontbonne University

MO

Student Financial Aid Matching / Level of Effort / Earmarking Cash Management

Corrective Action Plan 2024-003: The University concurs with the finding and has made the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed ...

Corrective Action Plan 2024-003: The University concurs with the finding and has made the required corrections to the COD disbursement dates. The University process when posting Aid has remained consistent each year, this appears to be an isolated incident where CAMS did not pick up the date listed on the disbursement screen for these students and pass that to COD. The University has implemented a control to complete the disbursements each time and then verify the date reflects correctly in COD afterwards. While this should be an automatic process, and has been in previous years, it will be something the University verifies now with each aid posting. Completion Date: August 2024 Contact Person: Megan Morton, Director of Financial Services

View Audit 348677

Finding 537461 (2024-002)

Significant Deficiency 2024

Fontbonne University

MO

Student Financial Aid Special Tests & Provisions Internal Control / Segregation of Duties

Corrective Action Plan 2024-002: The University concurs with the finding. The University has corrected the two Spring 2024 RT24 calculations and initiated additional Pell grant disbursements to the noted students. The University has updated its calculations of the scheduled breaks for the 2024-2025 ...

Corrective Action Plan 2024-002: The University concurs with the finding. The University has corrected the two Spring 2024 RT24 calculations and initiated additional Pell grant disbursements to the noted students. The University has updated its calculations of the scheduled breaks for the 2024-2025 academic year. Completion Date: August 2024 Contact Person: Megan Morton, Director of Financial Services

View Audit 348677

Finding 537460 (2024-003)

Significant Deficiency 2024

State System of Higher Education, Commonwealth of Pennsylvania

PA

Matching / Level of Effort / Earmarking Student Financial Aid Significant Deficiency § 200.303

Commonwealth: Direct Loan processor will submit monthly reconciliations to Executive Director of Financial Aid or designated campus director for review and approval

View Audit 348667

Finding 537458 (2024-002)

Significant Deficiency 2024

State System of Higher Education, Commonwealth of Pennsylvania

PA

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

ESU: The University acknowledges this is a repeat finding. While a corrective action plan was implemented in May 2024, the audit sample consisted of students from Fall 2023 and Spring 2024, before the updated procedures were in effect. Since then, the University has enhanced its process for identify...

ESU: The University acknowledges this is a repeat finding. While a corrective action plan was implemented in May 2024, the audit sample consisted of students from Fall 2023 and Spring 2024, before the updated procedures were in effect. Since then, the University has enhanced its process for identifying when a student ceases participation in a course. Faculty are now required to indicate when a student stops attending. If a faculty member and student agree on issuing an incomplete grade, both must sign a document attesting that the incomplete is a valid final grade. This ensures clarity for the Registrar's Office. Registrar staff now update the National Student Clearinghouse promptly once a student’s last date of activity is confirmed, particularly when a student withdraws from all courses. This process supports timely compliance with the 60-day federal reporting requirement. Additionally, the University is reviewing its procedures for reporting program enrollment effective dates to ensure consistency with NSLDS standards. All updates are submitted through the National Student Clearinghouse. IUP: IUP will set guidelines that all degree clearing must be done with the 45 day time line so the students are reported within the 60 days limit Cheyney: Cheyney University of Pennsylvania extracts current enrollment information, including any enrollment status changes for all students from the University system of record based on the schedule timeline provided to NSC. As of Fall 2024, The Registrar’s Office continues to review NSC information following transmission, particularly for effective dates of completely withdrawn students. The NSC reports enrollments to NSLDS for the University. Cheyney University had previously learned that NSLDS did not receive students' enrollment status changes from NSC in a timely manner due the University HCM2 status and timing of students being reported to NSLDS from COD based on Ed’s approval of the University HCM2 submissions Kutztown: We will shorten our process to 2-3 days to compensate from the (up to) 30 day lag between NSC reporting and NSLDS reporting. We will connect with another PASSHE school (not on the findings report) to ascertain how they keep their submissions timely, and learn best practices. We will renew our cooperative efforts with financial aid to ensure both sides of the equation – NSC and NSLDS – are communicating and that both offices are involved in double checking. Commonwealth: The issues with enrollment reporting were one-time issues related to the integration of the three schools and the implementation of and data migration to a new student information system. Issues have been resolved and Commonwealth University is currently reporting on the prescribed schedule Millersville: The Registrar’s Office will evaluate their procedures and review policies surrounding reporting status changes to NSLDS to ensure the enrollment effective date reported to NSLDS is aligning with the University’s last date of attendance. Primarily, the frequency of submissions to the NSC.

View Audit 348667

Finding 537456 (2024-001)

Significant Deficiency 2024

State System of Higher Education, Commonwealth of Pennsylvania

PA

Student Financial Aid Reporting Significant Deficiency § 200.303

ESU: The University acknowledges this is a repeat finding. In response, updated policies and procedures were implemented in May 2024. The audit sample included students from Fall 2023 and Spring 2024—periods that predated the implementation of the corrective measures. To improve compliance, the Univ...

ESU: The University acknowledges this is a repeat finding. In response, updated policies and procedures were implemented in May 2024. The audit sample included students from Fall 2023 and Spring 2024—periods that predated the implementation of the corrective measures. To improve compliance, the University has introduced enhanced reporting mechanisms to identify when a student is no longer participating in any enrolled courses during a given semester. Once a determination is made that a student has withdrawn, University Registrar staff manually update the student’s status in the National Student Clearinghouse. This process reduces the delay between a student’s actual withdrawal and the status update reported to NSLDS. These steps are intended to ensure timely and accurate reporting moving forward. IUP: IUP will set guidelines that all degree clearing must be done with the 45 day time line so the students are reported within the 60 days limit. Cheyney:Cheyney University of Pennsylvania utilizes the National Student Clearinghouse as a third-party service provider for enrollment reporting and provides all enrollment data to NSC, believing that enrollment would be reported to NSLDS in compliance with federal regulations; unfortunately, the enrollment data from the NSC roster which is provided to National Student Loan Data Systems (NSLDS), is only matched to students who currently have existing enrollment records in NSLDS. Student enrollment information is provided to NSLDS from Common Originations and Disbursements (COD). Cheyney University is a Heightened Cash Monitoring 2 (HCM2) institution, and students' Title IV aid/ disbursements are reported differently than advance pay institutions. The student records from COD are only provided to NSLDS upon approval of disbursement from Ed after the University HCM2 submissions are approved. As of Fall 2024, Cheyney University has continued to directly report and upload enrollment for all Title IV recipients to NSLDS from the monthly NSC enrollment rosters. Kutztown: We will target shortening our status change reporting process to 2-3 days to compensate from the (up to) 30 day lag between NSC reporting and NSLDS reporting. We will connect with another PASSHE school that was on the findings report for the last period - but not this period - to ascertain how they avoided the repeat, and to learn additional best practices. We will renew our cooperative efforts with financial aid to ensure both sides of the equation – NSC and NSLDS – are communicating and that both offices are involved in double checking Commonwealth: The issues with enrollment reporting were one-time issues related to the integration of the three schools and the implementation of and data migration to a new student information system. Issues have been resolved and Commonwealth University is currently reporting on the prescribed schedule. Millersville: The Registrar’s Office will review its reporting procedures to ensure that students’ statuses are timely reported to NSLDS as required by Federal regulations. Primarily, the frequency of submissions to the NSC.

View Audit 348667

Finding 537453 (2024-003)

Significant Deficiency 2024

Saint Peter's University and Affiliates

NJ

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

STEM - PODER – Federal Assistance Listing Number 84.031C Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreemen...

STEM - PODER – Federal Assistance Listing Number 84.031C Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is in the process of developing and implementing a formal policy and procedure to verify that a vendor is not debarred or suspended in the System for Award Management (SAM) database. The procedure, which will be in place by the end of FY 2025, will outline roles, responsibilities, and documentation requirements to ensure consistent compliance. Name(s) of the contact person(s) responsible for corrective action: Diane DiStaulo, Director of Accounting Operations, (201) 761-7415 Planned completion date for corrective action plan: by the end of FY2025

View Audit 348651

Finding 537447 (2024-002)

Significant Deficiency 2024

Saint Peter's University and Affiliates

NJ

Questioned Costs Student Financial Aid Significant Deficiency

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 ...

Student Financial Aid Cluster – Federal Assistance Listing Numbers 84.007, 84.033, 84.063 and 84.268 Recommendation: We recommend the University review its policies and procedures related to outstanding student refund checks to ensure they are being returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has developed a policy to identify uncashed Title IV refund checks prior to the 240-day expiration date. The policy includes steps to contact students whose checks did not clear and to return the refunds to the Department within 240 days after the issue date of the check. The procedures will ensure that reviews are completed and returned timely according to applicable regulations. Name(s) of the contact person(s) responsible for corrective action: Lillian Perreira-Talty, Director of Student Accounts (201) 761-6080 Planned completion date for corrective action plan: Completed

View Audit 348651 Questioned Costs: $1

Corrective Action Plans

Filters