Corrective Action Plans

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Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 2006, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and add...
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 2006, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting firm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Significant Deficiency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 2002, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and add...
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 2002, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting firm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Significant Deficiency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.
Processes have been implemented to improve and maintain documentation for grant reimbursement requests so overclaiming federal funds does not occur.
Processes have been implemented to improve and maintain documentation for grant reimbursement requests so overclaiming federal funds does not occur.
Processes have been implemented to improve and maintain documentation for grant reimbursement requests so overclaiming federal funds does not occur.
Processes have been implemented to improve and maintain documentation for grant reimbursement requests so overclaiming federal funds does not occur.
Processes have been implemented to improve and maintain documentation for grant reimbursement requests so overclaiming federal funds does not occur.
Processes have been implemented to improve and maintain documentation for grant reimbursement requests so overclaiming federal funds does not occur.
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 2001, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and add...
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 2001, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting firm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Significant Deficiency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing DEL II, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and addr...
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing DEL II, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting firm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Significant Deficiency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.
Finding 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Material to the Financial Statements: ...
Finding 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant deficiency in Internal Control over Compliance for Special Tests and Provisions Finding 2025-002 (continued) Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least 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 sections 982.158(d) and 982.405(b)). These inspection reports are required to be maintained and available for examination at the time of audit. For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were units that were not inspected within the annual inspection period. Additionally, there were units that failed inspections and did not pass reinspection within 30 days without penalty. Context: There are approximately two thousand seven hundred fifty six (2,756) units. Of a sample size of thirty seven (37) files, three (3) annual inspections, were not completed in a timely manner. Additionally, there are approximately one thousand two hundred forty seven (1,247) units with failed inspections. Of a sample size of twenty five (25) units with failed inspections, four units (4) unit did not pass reinspection within 30 days. Housing assistance payments were not abated nor was the tenant relocated. Our sample size is statistically valid. Cause: The Authority did not perform timely annual inspections and follow up to failed inspections in accordance with program requirements. Effect: The Housing Voucher Cluster Program is in non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance related to HQS inspections in accordance with the Uniform Guidance and the compliance supplement. Authority's Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies related to HQS inspections are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing DE 2003, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and add...
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing DE 2003, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting firm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Significant Deficiency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 99, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and addre...
Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 99, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting firm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The findings from the June 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Significant Deficiency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.
Wheeler Clinic, Inc. has reviewed the current approval processes. As of October 9, 2025, Wheeler Clinic, Inc. has formally implemented a process change removing any universal approval practices effective immediately. Wheeler Clinic, Inc. has also implemented a process that requires all managers/supe...
Wheeler Clinic, Inc. has reviewed the current approval processes. As of October 9, 2025, Wheeler Clinic, Inc. has formally implemented a process change removing any universal approval practices effective immediately. Wheeler Clinic, Inc. has also implemented a process that requires all managers/supervisors to authorize timesheets by a designated time on the subsequent Monday of the payroll cycle prior to payroll processing in order for payroll to be processed.
Finding 2025-002 – Maintenance of Effort Significant Deficiency | Federal Program: Title I, Part A (84.010) Response Steel City Academy recognizes that Maintenance of Effort (MOE) calculations rely on accurate cash-basis expense data reported on the Form 9 and that prior inaccuracies could impact ID...
Finding 2025-002 – Maintenance of Effort Significant Deficiency | Federal Program: Title I, Part A (84.010) Response Steel City Academy recognizes that Maintenance of Effort (MOE) calculations rely on accurate cash-basis expense data reported on the Form 9 and that prior inaccuracies could impact IDOE’s calculations. 24 Beginning July 1, 2025, the School implemented comprehensive corrective actions to improve Form 9 reporting, fund balance accuracy, and expense classification by consolidating all financial activity into QuickBooks Online. All expenses are now recorded by the Finance Coordinator using fund, program, and object codes aligned with IDOE reporting guidelines, ensuring Form 9 expenses are fully supported by underlying financial records. To ensure accurate fund balances, audited reconciliation worksheets are used to validate beginning-of-year balances prior to Form 9 submission. Grant expenditures and remaining balances are reviewed monthly to ensure proper classification and alignment between expenses and recognized revenue. The School has also engaged directly with the IDOE Form 9 team for technical guidance. The Executive Director provides direct oversight and performs a final review of Form 9 submissions to ensure compliance with reporting guidelines. These corrective actions are designed to ensure accurate, reliable Form 9 reporting and to prevent recurrence of this deficiency in future reporting periods.
Corrective action has been completed. The Institute determined at the start of Academic Year 24-25 that transitioning to a third-party provider of financial aid solutions would be in its best interest. This engagement provides a team of professional financial aid operations and student service speci...
Corrective action has been completed. The Institute determined at the start of Academic Year 24-25 that transitioning to a third-party provider of financial aid solutions would be in its best interest. This engagement provides a team of professional financial aid operations and student service specialists, allowing for enhanced loan counseling and processing services, implementing additional checks and balances, and mitigating the potential for errors such as this incident. The error resulting in the finding was actually identified by the third-party provider, following which AFI immediately returned the erroneously awarded federal funds to G5. Individuals responsible for corrective action: Lang Fredrickson, Chief Financial Officer 323.856.8429
Recommendation: We recommend the District maintain records that all vendors are not on the suspended or debarred listing. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensu...
Recommendation: We recommend the District maintain records that all vendors are not on the suspended or debarred listing. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensure records are retained for verification compliance. Name of the contact person responsible for corrective action: Lauren Syrup, Business Manager Planned completion date for corrective action plan: June 30, 2026
Recommendation: We recommend the District have someone reviewing all Clics reports before they are submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensure the Clics...
Recommendation: We recommend the District have someone reviewing all Clics reports before they are submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensure the Clics reports are reviewed before submission. Name of the contact person responsible for corrective action: Lauren Syrup, Business Manager Planned completion date for corrective action plan: June 30, 2026
Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services s...
Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services staff. • Roles and responsibilities for ConApp enrollment data review have been clarified to prevent future manual errors. Preventive Measures to Avoid Recurrence: 1. Dual Verification of ConApp Enrollment Data • The Accountant in Fiscal Services will now compare and confirm the ConApp enrollment counts to certified CALPADS Fall 1 data before submission and certification. • A second-level review by the Coordinator of Teaching and Learning Department certifying the ConApp. 2. Documentation & Recordkeeping • Any adjustments to pre-populated enrollment numbers will require written justification and supporting documentation (e.g., CALPADS reports, email confirmations). Responsible Parties: • Fiscal Services Accountant – Responsible for matching the ConApp enrollment counts to CALPADS Fall 1 and maintaining backup documentation. • Coordinator, Teaching and Learning Department – Support in verifying site-level data. Completion Date: • Immediate clarification and assignment of review responsibilities were completed in October 2025.
Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Reviewing Source Data: o The individual reviewing the documentation is different than...
Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Reviewing Source Data: o The individual reviewing the documentation is different than the individual who prepares the documentation. o When reviewing the documentation to be used when submitting reimbursement requests to the state, the reviewer will be required to compare this documentation to the organization’s ERP system. This is the official source of record for all reimbursement requests. Anticipated Completion Date: This process was fully implemented at the beginning of November 2025.
Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Scanning Applications: o CSFP staff scan applications daily. These applications are t...
Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Scanning Applications: o CSFP staff scan applications daily. These applications are then stored in SharePoint. We have 2-3 volunteers weekly who rename applications based on Client ID, Name, and Expiration Date, then file them electronically based on their expiration date. This ensures that we are always up to date on having an electronic version of our CSFP applications. o Before shredding any applications that have been scanned, we confirm that the application exists in the system (done by CSFP staff).  If an application is missing: o Confirm that application information is in ClientTrack and document through a generated printed application. o Send application to distribution site for next distribution, to ensure participant signs new application before they receive another CSFP box. Anticipated Completion Date: This process was fully implemented at the end of May 2024. It should be noted that the applications have a 3-year certification period, so the full effect of the new process won’t be realized until spring of 2027.
Return of Title IV (R2T4) Calculations Planned Corrective Action: SEBTS will take the following steps to address the failure to properly complete R2T4 calculations and returns: We will redefine an FI grade as “Failure due to inactivity” in the Faculty Handbook and Academic Catalog. Students will ear...
Return of Title IV (R2T4) Calculations Planned Corrective Action: SEBTS will take the following steps to address the failure to properly complete R2T4 calculations and returns: We will redefine an FI grade as “Failure due to inactivity” in the Faculty Handbook and Academic Catalog. Students will earn an FI if they fail the class due to lack of attendance or participation. The Provost will remind faculty during the final Faculty Meeting of each academic semester about the FI grade. The Registrar’s Office will send an email to all Faculty and Faculty Support Specialists during the last week of classes to remind faculty about assigning an FI to students who failed the course due to inactivity. The Instructional Design Office will inform Faculty Support Specialists about the FI grade during scheduled training meetings throughout the semester. The Adjunct Faculty Support Specialist will inform adjunct faculty during the final week of classes about the FI grade. The Registrar’s Office has updated Self Service, so faculty must enter the last date of attendance/participation if they enter an FI or F grade. The Registrar’s Office will use this to audit and only request further details from faculty who assign an F and indicate that a student stopped attending/participating before the end of the semester. The Learning Activity Report will be adjusted so Academic Advising can send a check-in email after 2 weeks of inactivity, a warning email after 3 weeks of inactivity, and the professor can assign an FI after 4 weeks of inactivity. Person Responsible for Corrective Action Plan: David Phillips, Director, Student Resources & Financial Aid Anticipated Date of Completion: 12/19/2025
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. Not al...
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. Not all dining locations had their final meal counts completed before the meal claim was submitted. The persons responsible for the corrective action are Aaron Burnett, the Food Service Director and Emily Kearney, the Business Manager. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that all meal counts are final on the Z-Report before the claim requests are made.
Finding 2025-006 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Activities Name of Contact Person: Tamara VanderPool, Payroll Director and Lisa Pearce, Business Manager Root Cause: **Insufficient staffing level. Inconsistent application of the personnel action form...
Finding 2025-006 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Activities Name of Contact Person: Tamara VanderPool, Payroll Director and Lisa Pearce, Business Manager Root Cause: **Insufficient staffing level. Inconsistent application of the personnel action forms and required documentation for changes to payroll details. Corrective Action Plan: • Clarify roles and responsibilities regarding payroll processing. • Establish a review process of all payroll transactions and documentation. Proposed Completion Date: Fall of 2025.
Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Pr...
Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Program 84.038 - Federal Perkins Loan Program 84.063 - Federal Pell Grant Program 84.268 - Federal Direct Student Loans Criteria: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their informationsharing practices to their customers and to safeguard sensitive data (16 CFR 314). institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with few that 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution's written information security program must address the implementation ofthe minimum safeguards identified in 16 CFR 314.4(c)(l) through (8) including: assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16CFR 314.4(d)). Condition/Context: Under a college's Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned Costs: Not applicable. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The Corporation's students' personal information could be vulnerable. Recommendation: We recommend the Corporation review each element of GLBA to ensure compliance with all necessary requirements. Corrective Action Plan: Corrective Action Planned: To ensure continued GLBA compliance the Corporation contracted with FRSecure to develop a risk assessment and roadmap which did a system scan for issues, an assessor interviewed staff including IT, HR, Finance Leaders and others to learn more about the current state of overall security program. Compliance with GLBA was part of their review. FRSecure issued an assessment 'Roadmap Plan' for the department to review and the Corporation will implement the results as feasible. Name of the contact person responsible for corrective action: John Sehloff, Director of Information Technology Anticipated Completion Date: June 30, 2026
Condition: The School District charged an expenditure to the grant which was incurred in a school building that was not an eligible school building under the award. Planned Corrective Action: Associate Accountant will ensure the Assistant Superintendent’s signature is on all invoices charged to fede...
Condition: The School District charged an expenditure to the grant which was incurred in a school building that was not an eligible school building under the award. Planned Corrective Action: Associate Accountant will ensure the Assistant Superintendent’s signature is on all invoices charged to federal grants including the Regional Assistance Grant. The Finance Director will ensure this during the invoice approval process. Finance Director and Assistant Superintendent meet monthly to discuss federal grants which includes the Regional Assistance Grant. Part of this meeting is to discuss known expenditures for federal grants so far this year to ensure they are properly coded and expended. Finance Director will run a general ledger analysis every two months to compare posted grant expenditures to approved grant budgets. Expenditures in question will be discussed at monthly meetings. Any determined to be incorrect will be moved to non-grant accounts via journal entry most likely prepared by Finance Director and approved by Associate Accountant. Contact person responsible for corrective action: RJ Wiersema and Jill Ansel Anticipated Completion Date: 12/31/2025
Management agrees with the finding and will establish the recommended procedure outlined in the Schedule of Findings and Questioned Costs.
Management agrees with the finding and will establish the recommended procedure outlined in the Schedule of Findings and Questioned Costs.
Identifying Number: 2025-002 Audit Finding: Per the U.S. Department of Agriculture at 7 CFR 226.16(d)(4) and the Missouri Department of Health and Human Services, sponsoring organizations must conduct three monitoring review visits for each of their facilities and no more than six months may lapse b...
Identifying Number: 2025-002 Audit Finding: Per the U.S. Department of Agriculture at 7 CFR 226.16(d)(4) and the Missouri Department of Health and Human Services, sponsoring organizations must conduct three monitoring review visits for each of their facilities and no more than six months may lapse between monitoring visits for CACFP compliance. At least two of the three reviews must be unannounced. If a violation occurs during the visit, the sponsor must follow up with the facilities noted as having problems, and the follow-up visit must be conducted no less than one week after the initial finding, and the visit must be documented. Kansas City Public Schools did not perform the required three site visits per year within a six-month timeframe for five of the samples, and the supporting documentation provided for all six samples did not contain the total of participants in attendance during the meal service and the total number of meals claimed during the five consecutive days. Corrective Actions Taken or Planned: The District agrees with the finding. The District will implement and strengthen the following internal controls to ensure that all three required visits are accurately documented using the DHSS Site Visit Report by June 30, 2026: a. Training: Child Nutrition Services (CNS) will review and provide training to all supervisors and department leaders on DHSS Sponsor Review requirements. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance b. SOP: CNS will utilize a central repository [CNSReporting@kcpublicschools.org] to streamline and time-stamp audit submissions. The original copy will be stored in a designated binder, and a digital copy will be retained in the CNS shared drive. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance c. Monitoring: C CNS leaders, as designated by the Officer of Nutrition & Compliance, will conduct Supper audits during SY 2025–2026 in September, December, and March. Snack audits will be conducted in November, February, and April. Additional audits will be scheduled as necessary to ensure compliance with program requirements. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance d. Reporting: As part of progress monitoring, at the end of each monitoring month, each applicable site will be reviewed to confirm completion & accuracy of a Sponsor Review. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance
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